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.
To support the client, we helped to assess gaps in their due diligence system against the EUBR and provided guidance on updated policy and how to implement it with suppliers. We gave the company a clear roadmap for compliance ahead of the EUBR timeline. We did this through the following steps:
- EUBR diagnostic: Using our diagnostic methodology, we conducted a gap analysis of the group’s management systems against the due diligence requirements of the EUBR to assess the client’s readiness. This involved reviewing documents and interviewing staff to assess how relevant policies and processes were implemented.
- EUBR policy: We developed a due diligence policy that aligned with the Regulation’s requirements and established the group’s commitment, standards, and procedures to conduct due diligence in its battery supply chain.
- Supplier briefing note and contractual clauses: We developed a briefing note to inform battery suppliers about the EUBR’s due diligence and traceability requirements and prepare them for future contractual obligations. We included a questionnaire to assess their knowledge of their supply chain and identify any potential challenges to their ability to meet the EUBR’s requirements.
- 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.
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.
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How exposed are electronics companies to the EU Batteries Regulation?
Any company placing batteries or battery‑containing products on the EU market is affected. Indirect exposure through suppliers is common.
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What is the biggest challenge in electronics supply chains?
Limited visibility beyond Tier 1 suppliers is the primary challenge. Battery components often originate far upstream.
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Is risk scoping really necessary?
Yes. Risk scoping is how companies demonstrate proportionality and avoid spreading effort too thinly.
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What happens if data is incomplete?
Incomplete data is expected initially. The key is showing improvement over time backed by a clear plan.
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How does this link to wider ESG due diligence?
The regulation reinforces broader expectations around ongoing, risk‑based due diligence.
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Can this be integrated with existing ESG programmes?
Yes, and integration is strongly encouraged to avoid duplication.
