European UnionDelayed
Corporate Sustainability Due Diligence Directive
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
Read →The tracker · European Union
Mandatory raw material supply chain due diligence for batteries covering cobalt, lithium, nickel and natural graphite.
Due diligence applies from 18 August 2027; the Commission guidelines were due on 26 July 2026 and we cannot confirm that they were published.
In plain language
The Batteries Regulation includes a due diligence chapter modelled on the OECD minerals guidance, requiring battery producers to establish management systems, identify and mitigate risks in cobalt, lithium, nickel and natural graphite supply chains, and have their policies verified by notified bodies.
Regulation (EU) 2025/1561 postponed the due diligence obligations to 18 August 2027 and moved the deadline for the Commission guidelines to 26 July 2026. A separate Omnibus IV proposal, which would exempt operators below EUR 150 million in turnover and reduce public reporting to once every three years, is still in the legislative process and is not yet law. The direction of travel is unchanged even so: mineral supply chains feeding the EU battery market will need documented, audited due diligence reaching mine level.
Obligations
Producers must adopt and communicate a due diligence policy for the four covered raw materials, aligned with OECD guidance.
Due diligence policies require verification by a notified body, with periodic reassessment.
Annual public reports on due diligence findings and mitigation are required.
Timeline
Regulation entered into force.
Regulation began applying generally, with obligations phased over subsequent years.
Regulation (EU) 2025/1561 postponed the due diligence obligations by two years.
Deadline for the Commission due diligence guidelines. We have found no published guidelines as of October 2026, and we will record them here when they appear.
Battery passport requirements apply to covered battery categories.
Supply chain due diligence obligations apply to economic operators.
Changelog
Corrected the claim that the 2025 regulation adjusted thresholds: the EUR 150 million exemption and three-yearly reporting are still proposals. Noted that the guidelines deadline of 26 July 2026 passed without confirmed publication.
Entry updated after the postponement of the due diligence chapter was confirmed.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Same jurisdiction
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
Read →Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
Read →Leather left the scope on 18 September 2026, when Delegated Regulation (EU) 2026/2102 entered into force.
Read →