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Salomé Wyns

Senior Consultant

Ethan Ijaz

Consultant

Jean-Baptiste Collovray

Senior Consultant

CASE STUDIES

EU Batteries Regulation: Alignment of electronics multinational


When new policy meets old supply chains…

A multinational electronics group commissioned us to help prepare for the EU Batteries Regulation (EUBR). The group manufactures batteries and consumer electronics that contain batteries. Europe is an important market for the group, so they wanted to get ahead of the enforcement of due diligence obligations on 18 August 2025. The client’s key concern was how to implement an updated policy within their complex supply chain and ensure that suppliers understood their obligations and what was being asked of them in any updated contractual clauses.

  • We reviewed the group’s existing contracts and drafted EUBR-specific clauses to be cascaded down the supply chain. These clauses laid out the obligations of suppliers to support the group in complying with the legal requirements of the Regulation, from gathering chain of custody information to carrying out risk assessments and risk response measures.
  • Kumi developed battery supply chain maps and risk assessments (including key sourcing geographies, technology trends, and market features) for each of the four battery materials within the scope of the EUBR (cobalt, lithium, nickel, and graphite). Then, based on the material composition of the batteries provided by suppliers, a selection of supplier risk profiles was developed. The profiles assessed suppliers’ responsible sourcing maturity.

We also provided a roadmap of the activities the group would need to implement by 18 August 2025 to align with the due diligence obligations of the EUBR.

EU Batteries Regulation: Alignment of electronics multinational

A clear way forward

The client received a clear action plan to align with the EUBR’s due diligence requirements. By helping the group to develop a realistic and tailored strategy to navigate issues and pursue continuous progress, our client is already ahead of many of its peers in aligning with the EUBR and is helping to shape what good practice looks like in its sector.