CASE STUDIES

Risk scoping and supplier engagement under the due diligence obligations of the EUBR

EUBR Due Diligence for Battery Supply Chains

SUMMARY: This case study explains how risk scoping and supplier engagement can support compliance with the EU Batteries Regulation (EUBR). It shows how companies selling battery-powered products in the EU can identify high-risk supply chain areas, prioritise suppliers and begin meaningful due diligence, even with limited traceability and incomplete supplier data.

 

We supported a global e-commerce company to establish a robust foundation for EU Batteries Regulation (EUBR) compliance. We created a risk-scoping and supplier prioritisation framework, including initial engagement, and the company gained visibility into high-risk areas and actionable insights for future due diligence. This approach positioned the organisation to scale compliance efforts effectively and demonstrate the start of a continuous improvement process.

Who was the client?

A leading global e-commerce company operating across multiple markets, with a significant and growing portfolio of battery-powered products sold in the EU.

What was the problem?

The company faced new regulatory requirements under the EUBR, demanding transparency and risk management across complex battery supply chains. Internal traceability was limited, and external pressures included compliance deadlines and reputational risks. With fragmented supplier data and without a clear risk baseline, prioritising risks and engaging suppliers effectively was challenging given the size and complexity of the in-scope supply chain.

EUBR Compliance for Automotive Parts Manufacturers

What was implemented?

A two-part solution was delivered:

  • Risk-scoping tools: A detailed report and interactive dashboard mapping high-risk geographies, supply-chain stages and battery materials.
  • Supplier prioritisation, including engagement pilot: Development of a documented sampling approach followed by engagement materials such as FAQs, templates and a screening process to identify and assess battery manufacturers supplying EU retail operations.

These tools provided clarity on risk priority areas and practical steps for vendor engagement, supported by lessons learned and guidance for scaling due diligence.

What changed as a result?

  • Built a baseline for risk prioritisation aligned with EUBR requirements by using innovative sampling approaches, allowing the client to kick-start the risk assessment process despite high supply chain complexity and limited transparency.
  • Identified major battery manufacturers and created profiles to provide initial supplier-specific information that enabled the client to prioritise suppliers for targeted engagement.
  • Achieved early insights from supplier outreach, including response rate and usable manufacturer data to improve the developed approach and refine it for future application.
  • Based on project results, developed an outline and next steps for completing the full risk management process, including supplier engagement and training.

What does this mean for others?

This case demonstrates that meaningful due diligence doesn’t have to wait for perfect data and acknowledges that it never will be perfect. Starting with risk scoping, innovative prioritisation techniques and supplier engagement can help to improve visibility and identify points of leverage so that the companies can proactively influence where it matters and drive positive impact. By moving beyond box-ticking and investing in supplier relationships, organisations can uncover hidden risks, avoid reputational damage and build trust across the supply chain, whilst demonstrating continuous improvement efforts in line with regulatory requirements of the EU Batteries Regulation.

“Meaningful due diligence under the EUBR doesn’t require perfect data to begin; risk scoping is necessary to first establish a risk baseline that can then inform targeted supplier engagement and data collection.”

 

Frequently asked questions

  • How do we engage suppliers for EU Batteries Regulation compliance?

    Supplier engagement should be phased, risk‑based, and clearly linked to regulatory requirements. Asking for everything at once often leads to resistance or poor data quality.

  • What if suppliers say they don’t have the required data?

    This is common, especially in complex battery value chains. Companies are expected to demonstrate reasonable efforts, not perfect data from day one.

  • When should supplier engagement start?

    As early as possible. Mapping suppliers and clarifying expectations takes time and cannot be rushed close to enforcement deadlines.

  • How do we prioritise which suppliers to engage first?

    Prioritisation should be based on risk factors such as material type, geography, and supply chain position. This aligns with regulatory expectations for proportionality.

  • Does the regulation require contract changes?

    Often yes. Updated contractual clauses are a key tool for clarifying supplier obligations under the regulation.

  • What does “credible progress” look like to regulators?

    Clear scoping, documented engagement, and practical next steps show more credibility than claiming full compliance too early.

Ethan Ijaz

Contact Ethan