The tracker · European Union

EU Batteries Regulation (due diligence provisions)

DelayedEuropean UnionEntry updated October 2026

Mandatory raw material supply chain due diligence for batteries covering cobalt, lithium, nickel and natural graphite.

Status
Delayed
Enacted
August 2023
First compliance deadline
18 August 2027 (due diligence chapter)
Companies in scope
Economic operators placing batteries on the EU market, with an exemption for smaller operators; a pending proposal would extend that exemption to operators below EUR 150 million turnover
Maximum penalty
Set by member states; market withdrawal available
Civil liability
Administrative enforcement through market surveillance
Enforcement body
National market surveillance authorities and notified bodies

Latest movement

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

What this law does

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

What it asks of companies

  1. Supply chain due diligence policy

    Producers must adopt and communicate a due diligence policy for the four covered raw materials, aligned with OECD guidance.

  2. Third-party verification

    Due diligence policies require verification by a notified body, with periodic reassessment.

  3. Public reporting

    Annual public reports on due diligence findings and mitigation are required.

August 2023

Regulation entered into force.

February 2024

Regulation began applying generally, with obligations phased over subsequent years.

July 2025

Regulation (EU) 2025/1561 postponed the due diligence obligations by two years.

26 July 2026

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.

18 February 2027

Battery passport requirements apply to covered battery categories.

18 August 2027

Supply chain due diligence obligations apply to economic operators.

Changelog

Entry history

October 2026

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.

March 2026

Entry updated after the postponement of the due diligence chapter was confirmed.

Trade under this regime · Regulated Trade Index

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

$42bn
Vietnam$20bnIndia$11bnThailand$8.7bnIndonesia$1.9bnBrazil$0.6bnBangladesh$0.0bn

Sources

Primary documents

Same jurisdiction

Related regimes