What Does EU Battery Regulation Due Diligence Require From Suppliers?

EU Battery Regulation creates two supplier-facing obligations for companies that place batteries on the EU market, including batteries inside products:

1. Supply chain due diligence from 18 August 2027, for companies with a net turnover of €40 million and over, covering basically every battery type you place on the market (phones, SLI, most medical devices, e-bikes, industrial packs, EV). This is the obligation that requires tracking four materials in those batteries: cobalt, natural graphite, lithium, and nickel, through a chain-of-custody system. In practice, that means getting an EMRT or similar disclosure back from battery suppliers every year. The regulation then requires you to turn those disclosures into a risk profile for your suppliers and a plan for how you handle that risk.

2. Battery passport from 18 February 2027, only for bigger / traction batteries (LMT such as e-bikes, industrial over 2 kWh, EV). No €40 million threshold here. Smaller portable packs usually skip the passport, but they still sit under due diligence if you clear that turnover test. This article focuses on the first obligation.

After collecting and scoring the received EMRTs, your organization has to report the findings to top management and have a plan for suppliers that stay high-risk or will not disclose: pressure, tracked improvement, and in the last resort suspension.

Which batteries are in scope?

Due diligence covers every battery type you place on the EU market if you clear the €40 million turnover threshold. The passport covers only LMT, industrial batteries over 2 kWh, and EV batteries.

Let’s go through some examples:

Battery type	Examples	Due diligence (18 Aug 2027)	Battery passport (18 Feb 2027)
Portable (sealed, ≤5 kg)	Phones, most medical devices	Yes	No
SLI	Vehicle starter / ignition batteries	Yes	No
LMT (≤25 kg)	E-bikes, e-scooters	Yes	Yes
Industrial ≤2 kWh	Smaller industrial packs	Yes	No
Industrial over 2 kWh	Larger industrial and stationary packs	Yes	Yes
EV	Electric vehicle traction batteries	Yes	Yes

The due diligence deadline was postponed

When the Batteries Regulation was adopted in 2023, supply chain due diligence was supposed to apply on 18 August 2025. Regulation (EU) 2025/1561 moved that date to 18 August 2027, and moved the Commission guidelines deadline to 26 July 2026. The stated reasons were missing notified bodies in about half of Member States and operators needing more preparation time.

The substance of the obligation did not change. You still need the chain-of-custody system, the four materials, notified-body verification, and a public report. What changed is the calendar. The battery passport date (18 February 2027) was not postponed.

A further Omnibus proposal (COM(2025) 501) would, if adopted, raise the Art. 47 turnover exemption from €40 million to €150 million and move the public due diligence report from annual to every three years. As of mid-2026 that package was still in the ordinary legislative procedure. Until it is law, plan against the €40 million threshold and the annual report.

What is a chain-of-custody system?

A chain-of-custody system is how you prove you know where the four covered materials came from, and who handled them on the way to your battery.

For each battery model, you should be able to document:

• Which supplier sold you the material (or the part that contains it)
• Which country the raw material came from
• The steps in the trading chain from the mine or extraction point to the company that sold it to you
• How much of each material is in that battery (cobalt, natural graphite, lithium, and nickel)

This is documented evidence for a notified body and for an annual due diligence report, not real-time tracking of every shipment. In practice, teams usually ask suppliers for the same kind of minerals disclosure already used for conflict minerals, then follow up until the file is complete enough to use.

If a link in the chain is missing, the file is incomplete. That is why this becomes a supplier engagement campaign, not only an internal policy document.

What you have to ask suppliers for

Article 49 is specific. Your controls need documentation that includes, for the covered materials in each battery:

1. Who supplied the material (name and address)
2. Country of origin of the raw material
3. Market transactions from extraction to your immediate supplier
4. Quantities of each material in the battery (percentage or weight)
5. Suppliers’ third-party verification reports when they exist

You also have to put due diligence and risk management into supplier contracts, run risk assessment against the Annex X topics (environment, labor, human rights, communities), get the policy verified by a notified body, and publish an annual report.

The collection half looks a lot like conflict minerals work. The risk management half is a separate job, and teams often miss that when they treat “get the EMRTs back” as the finish line.

What is an EMRT?

The regulation does not mandate one spreadsheet. In practice, the Responsible Minerals Initiative’s EMRT (Extended Minerals Reporting Template) is the free industry template teams use. It is the sibling of the conflict minerals CMRT. RMI expanded its mineral scope so companies can support EU Battery Regulation reporting. Current EMRT minerals include cobalt, copper, natural graphite, lithium, natural mica, and nickel. The four Annex X battery materials sit inside that set. Copper and mica are extra for broader minerals due diligence, not battery-regulation-only asks.

Teams that already run a CMRT campaign every year will recognize the shape: standard spreadsheet, named contacts at suppliers, follow-ups until a valid file lands, then cleanup when sections are missing. The main difference is maturity. CMRT is established, and suppliers know the process. EMRT programs for battery materials will usually start with colder contacts and more incomplete first returns.

Supplier Risk Assessments

Article 50 is titled risk management obligations, and it goes past collecting and filing the templates. Once the chain-of-custody data is in, you have to:

1. Identify and assess risks in the supply chain against Annex X
2. Report findings to named top management
3. Run a mitigation plan, pressure the suppliers who can actually reduce the risk, track whether it improved, and consider suspending or dropping a supplier if it did not
4. Reassess when circumstances change

In practice, the first automated triage layer on a returned EMRT is matching it against public lists:

• Smelter and refiner IDs against the RMI Active / Conformant / Eligible facility lists (including cobalt refiners)
• Country or region of origin against the EU indicative CAHRA list
• Supplier and facility names against public sanctions lists where relevant
• Incomplete or unusable disclosure treated as its own risk flag

A score like this tells you which suppliers need attention first, and which files are fine. It does not certify that your risk method is acceptable to a notified body. It is triage for the management decisions, not the finish line for Article 50.

What the guidance still leaves open

The harder gap sits one layer deeper, at mine-level due diligence. Guidance and OECD-aligned practice point teams at several pathways for that upstream work: rely on supplier third-party verification reports, join or lean on an industry scheme, or assess mines yourself. For a company many tiers downstream of extraction, “do it yourself” is usually not a serious option.

What is missing is an authority that says which pathway, and which risk measurement, is good enough. Under Article 53, the Commission can recognise industry due diligence schemes as equivalent. For conflict minerals, RMI’s RMAP already plays that de facto role, and has Commission recognition under the separate Conflict Minerals Regulation. For battery materials under the Battery Regulation, RMI is expanding templates and facility lists to fill the same void, but no battery scheme has Article 53 recognition yet.

So the honest split is: you can, and should, collect complete disclosures and triage them now. Deciding whether a mine-level risk method will survive notified-body review is still a legal and scheme-recognition problem, not something a spreadsheet score settles.

Whatever pathway you eventually pick, incomplete disclosure remains a problem. You cannot defend DIY assessment, supplier verification, or a recognised scheme if you do not know who is in the chain.

What people often overstate

Common assumption	What the regulation actually says
Continuous monitoring of every supplier	Annual report, plus refresh after a change of circumstances
Every material in every component	Four battery raw materials (and compounds used in active materials)
Everything hits at once at year-end 2027	Passport: 18 Feb 2027 (limited battery types). Due diligence: 18 Aug 2027 (postponed from Aug 2025)
CSDDD is the same obligation right now	Post-Omnibus, CSDDD applies from 26 July 2029 and only to very large companies (about 5,000 employees / €1.5bn turnover)

That does not mean the worry is invented. Article 50 is new for most teams at raw-material and mine depth, the upstream pathways exist but no battery scheme is Commission-recognised yet, and persistent non-compliance can keep non-compliant batteries (and the products that contain them) off the EU market. Building the supplier list, the request format, and the scoring workflow now still helps, even while the mine-level acceptability question is being settled.

A practical sequence for supplier engagement teams

1. Map which products contain in-scope batteries and which suppliers sit on the cobalt, graphite, lithium, or nickel path. The list is often smaller than the full sustainability vendor universe.
2. Pick the request format now (EMRT or an equivalent you can defend to a notified body).
3. Find the right person at each supplier. Managing directors and general sales inboxes are usually the wrong start for a minerals template. You want the same functional owners who already handle conflict minerals, EHS, or sustainability disclosures.
4. Run it like a campaign. First request, reminders, escalation when the contact is stale, validation when the return is incomplete, then close when the file is usable.
5. Score the returns. Match smelter IDs, origin countries, and entity names against the public lists above, and treat incomplete disclosure as a flag. That is triage for prioritization, not a certificate that your mine-level risk method is acceptable.
6. Separate passport work from due diligence work. Passport obligations hit a narrower battery set six months earlier. Passport tooling does not replace the supplier disclosure chase or the risk scoring you will need either way.

TL;DR

When does EU Battery Regulation due diligence start?

18 August 2027 for in-scope economic operators. The original regulation set 18 August 2025. That was postponed two years by Regulation (EU) 2025/1561.

Which materials are covered?

Cobalt, natural graphite, lithium, nickel, and chemical compounds based on them that are needed for battery active materials (Annex X).

Is there a standard supplier template?

Not in the regulation itself. The RMI EMRT is the free de facto industry template. It covers the four Annex X battery materials plus copper and mica.

What does chain of custody mean here?

It means you can document who supplied the covered materials, where they originated, and the trading steps back toward extraction, with quantities for each battery model. It is a recorded custody trail, not continuous live tracking.

Does the battery passport apply to medical device batteries?

Usually not for sealed portable batteries. The passport covers LMT, industrial batteries over 2 kWh, and EV batteries from 18 February 2027. Due diligence still applies when those portable batteries are placed on the EU market inside products.

Is collecting EMRTs enough for Article 50?

No. Article 50 requires you to assess the returns for risk, report findings to top management, and run mitigation. Matching smelter IDs and origin countries against RMI facility lists and the EU CAHRA list is the usual first triage layer. It does not settle whether your mine-level risk measurement is acceptable. The management decisions, and the choice of upstream due diligence pathway, still sit with you.

How Bridgecurrent solves this

Passport platforms and due diligence policies do not fill empty inboxes. The work that breaks teams is getting a complete EMRT (or equivalent) back from every battery and cell supplier, from the person who actually owns smelter and origin data, then reading those returns for risk signal instead of filing them unread.

Bridgecurrent runs that front end. We find the conflict-minerals, EHS, or sustainability contact at each battery supplier, send the request, follow up until a usable file lands, and check the return so blank tabs, wrong scope, or obvious junk do not get marked done. We also score returned EMRTs against the public lists that matter for triage: RMI facility status, EU CAHRA geography, and sanctions matches where relevant, with incomplete disclosure flagged on its own.

That score is prioritization, not a ruling that your risk method will survive a notified body. You still own the Article 50 decisions: which upstream pathway you use for mine-level diligence, who reviews the flags, what mitigation looks like, and when a supplier gets escalated or dropped. We make sure those decisions start from complete, triaged files rather than a pile of unopened spreadsheets. Whatever pathway you pick, you need to know who is in the chain first.

That is a different job from buying battery-passport software, and a different job from waiting for an Article 53-recognised battery scheme. Most medtech and device batteries never need a passport. Almost all of them still need the minerals disclosure and a way to turn incomplete returns into a worklist.

Sources

Dates and obligations below come from these primary sources. If a point matters for your compliance plan, read the text itself.

1. Regulation (EU) 2023/1542 and the consolidated version. Due diligence is Chapter VII (Arts. 47 to 52). Risk management is Art. 50. Passport is Art. 77. The four materials are in Annex X.
2. Regulation (EU) 2025/1561. This is the two-year postponement: due diligence moves to 18 August 2027, guidelines to 26 July 2026.
3. COM(2025) 501. Still a proposal. Would raise the turnover cut to €150m and stretch public reporting to every three years.
4. Commission page on the battery passport. Useful for who is actually responsible for passport data.
5. RMI EMRT. Free template most teams will end up sending. Current recommended version is v2.11 (April 2026).
6. RMI facility lists and the EU CAHRA resources RMI points to. Public inputs for scoring returned disclosures. Article 53 covers Commission recognition of industry schemes; none are recognised yet for battery materials under this regulation.
7. Commission CSDDD page and Directive (EU) 2026/470 for the post-Omnibus thresholds and the 26 July 2029 start.