CASE STUDIES

EU Battery Regulation: alignment of FMCG company

The Project

Kumi supported a leading FMCG company to begin its journey towards alignment with the EU Battery Regulation, in time for the release of the implementation guidelines next year. We worked with the client to understand its existing procurement processes, supplier relationships and responsible sourcing accountabilities through targeted engagement with internal stakeholders. We also wanted to identify battery-containing products relevant to the regulation and determine their material content for the four in-scope materials: lithium, nickel, cobalt and natural graphite.

For each of the four in-scope materials, Kumi:

Undertook desk-based research to determine relevant geographies for extraction, processing and manufacturing processes in the battery supply chain.
Assessed social and environmental risks associated with supply chain activities in each relevant geography.
Highlighted industry trends for key sources and forms of the materials and their potential impact on the future risk landscape.
Developed simplified supply chain maps for each material, including the different sources and forms.

Our recommendations

Kumi’s high-level risk assessment led to pragmatic recommendations for due diligence and risk management, recognising the maturity of the company’s responsible sourcing programme and its leverage over suppliers. Kumi presented a roadmap of the activities that would need to be implemented by 18 August 2025, when companies falling under the scope of the EU Battery Regulation must fulfil their due diligence obligations. The roadmap recognised when each employee, supplier and external stakeholder (e.g. affected parties and industry peers) should be involved in due diligence activities.

The outcome

The client has already been able to upskill its procurement team to engage with Tier 1 suppliers on supply chain transparency and to make targeted, consolidated requests for information (ROIs). Moving forward, the client can use this data to identify, prioritise and manage risks and be better positioned to mitigate potential impacts on the ground.

By developing a realistic strategy to navigate issues and pursuing continuous progress, the client is already ahead of many of its peers in aligning with the EC Battery Regulation and is helping to shape what good practice looks like in its sector.

Ethan Ijaz

For enquiries on this case study, contact Ethan

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