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Alex Graf

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James Lewry

Director

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Battery Materials


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EU Battery Regulation readiness

Powering the green transition, responsibly. Batteries. They are at the heart of the green transition. Pivotal for powering electric vehicles and storing renewable energy, the surge in battery demand shows no sign of slowing and is projected to grow by 74% by 2025. Batteries are a critical technology in our sustainable future. However, their production can create significant social and environmental risks in extracting critical materials like cobalt, lithium, and nickel.

Adverse impacts such as child labour, hazardous working conditions, water stress, and chemical spills pose significant risks to workers, local ecosystems, and communities in many countries where battery materials are extracted and processed.

Standing on the shoulders of extractive industry guidelines, new regulations, such as the EU Battery Regulation, are being introduced to improve the environmental footprint of battery production and enforce responsible sourcing practices. By integrating human rights into the supply chain requirements, the regulation helps to ensure that the push for a greener future does not come at the cost of exploitative labour practices and environmental degradation.

Kumi has supported due diligence in critical materials supply chains for nearly ten years. We work with downstream companies operating in – or reliant on – the mining sector to build responsible sourcing systems and assess upstream adverse impacts at the point of extraction and refining.

The European Commission has nominated Kumi to develop the Implementation Guidelines for the EU Battery Regulation. We are bringing our practical, on-the-ground insight into the upstream supply chain to shape this important policy agenda.

What batteries are in scope?

The EU battery regulation applies to all types of batteries placed on the market or put into service within the EU, regardless of their origin or whether they are manufactured in the EU or imported. This includes batteries incorporated into appliances, light transport, or other vehicles and batteries sold separately or used in products. This includes:

Portable Batteries: Used in consumer electronics and smaller devices.

Industrial Batteries: Use in larger-scale applications such as energy storage and industrial machinery.

Automotive Batteries: Used in vehicles for lighting, ignition etc.

Electric Vehicle Batteries: Specifically designed for use in electric vehicles.

Light Means of Transport Batteries (LMT Batteries): Include batteries in lighter electric vehicles such as e-bikes and e-scooters​​.