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James Lewry

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Alex Graf

Senior Consultant

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Battery Materials


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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 is the EU Battery Regulation?

The European Union’s Battery Regulation aims to ensure sustainability, safety, and environmental standards for all types of batteries sold within the EU, from small household types to large industrial ones. From a responsible sourcing perspective, companies must establish due diligence and risk management systems for their battery supply chains. The Regulation’s scope applies to the activities of all operators involved in the life cycle of batteries, such as producers, distributors, and end-users for all battery types, irrespective of their origin.

Under one part of the regulation, companies must identify and mitigate social and environmental risks linked to extracting, processing, and trading battery materials (nickel, cobalt, lithium, graphite) in line with international frameworks from UNEP, ILO, OECD, etc.

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​​.

 

What are companies required to do?

If your company places a complete battery product on the EU market, you are in the scope of the regulation and must conduct due diligence. This can include manufacturers, importers, distributors, and others who make batteries available on the EU market. From 2025, you will be gradually required to:

1. Comply with sustainability and safety standards: adhere to EU standards concerning battery sustainability, performance, and safety. This includes rules on the collection, recycling, and second-life use of batteries.

2. Adhere to carbon footprint and recycled content requirements: provide a carbon footprint declaration and meet recycled content targets for manufacturing processes.

3. Implement due diligence and responsible sourcing: develop due diligence policies to manage the sourcing of raw materials used in batteries, ensuring ethical practices that prevent adverse social and environmental impacts.

4. Meet end-of-life and recycling obligations: ensure that batteries are designed to optimise end-of-life handling to support recycling efforts related to waste batteries’ treatment, recycling, and disposal.

5. Ensure market surveillance and conformity: (economic operators) must ensure that all batteries placed on the market comply with the regulation. This includes conducting conformity assessments and providing documentation to show compliance.

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