EU Batteries Regulation

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Power the transition – responsibly

Prepare your battery supply chain for the EU Batteries Regulation (EUBR) and build robust due diligence systems that meet legal expectations while strengthening your supplier relationships.

Battery demand is accelerating and so are expectations for responsible sourcing. The EU Batteries Regulation (EUBR) requires certain economic operators, such as manufacturers and importers placing batteries on the EU market, to carry out supply chain due diligence. This means identifying and addressing environmental and human rights risks linked to cobalt, lithium, nickel, and natural graphite.

What is required from economic operators?

Companies above a certain annual net turnover (currently EUR 40m, likely to be increased) placing batteries on the EU market must implement and operationalise a set of management systems and processes by August 2027 (exception: public reporting).

These must be aligned with the principle of risk-based due diligence from international frameworks such as the OECD Due Diligence Guidance and the UN Guiding Principles for Business and Human Rights.

Companies have to identify and address a range of risks related to the environment, social and human rights, as well as business integrity. The EUBR stresses that regardless any use of tools, the responsibility to demonstrate robust due diligence remains with the economic operator placing the batteries on the EU market and cannot be shifted.

Risk-based due diligence under the EUBR focuses on making in-scope supply chains transparent, assessing risks, and acting to resolve issues where needed. This process must be guided throughout by clear prioritisation of the most significant risks and impact in your supply chain.

Continuous improvement of actual risks and impact is key, and businesses must be fit to implement the core management activities for achieving it.

In-scope economic operators also require third-party verification by a Notified Body to demonstrate the sufficient implementation of all management systems and processes.

How Kumi can help you

Kumi supports you across the entire due diligence lifecycle from initial stocktaking to preparation, ongoing implementation, and monitoring and improvement. The foundation of our work in OECD frameworks supports cross-regulatory applicability wherever possible.

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Our services

Cross-cutting:

  • EUBR gap assessment: We provide you with a clear and detailed assessment of your EUBR due diligence readiness and how to fill any gaps. Can be extended to other due diligence requirements.

Management systems:

  • Draft policies and commitment: We provide EU battery policy templates, which can be tailored and integrated into existing policies.
  • Supply chain mapping and verification: We design and implement data collection strategies to identify your supply chain beyond tier 1, aligned with EUBR requirements and applicable for broader due diligence.
  • Due diligence process flow design: We develop full due diligence systems from overarching process design to detailed documentation and governance.
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Our services continued

Management processes:

  • Supplier engagement: We support communication with suppliers on EUBR requirements, contractual clauses, and training on due diligence expectations.
  • Risk scoping of battery supply chain: We provide a ready-to-go EUBR-aligned risk scoping for the identification of indicative ESG risks and kick-start prioritisation.
  • Assessment and risk mitigation: We conduct in-depth assessments of high-risk suppliers (off- and onsite) and develop action plans for identified risks.
  • Capacity building: We help internal teams understand the implications of the EUBR and help build the practical knowledge needed for the implementation of due diligence.
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Why companies choose Kumi

We are helping write the rules

Kumi was appointed by the European Commission to develop the official EUBR Due Diligence Implementation Guidelines and the methodology for recognising due diligence schemes. We also supported in the development of the third-party verification process by notified bodies. This gives us unparalleled insight into what the Commission expects.

Nearly a decade of experience in battery and critical‑mineral due diligence

We have supported companies across mining, manufacturing, e‑mobility, electronics, FMCG, and retail to map supply chains, assess upstream risks, and build scalable due diligence systems.

Recognised expertise in responsible sourcing

Clients value our technical depth, operational insight, and on‑the‑ground experience supporting suppliers and sites around the world.

Missed our webinars?

Due Diligence under the EU Batteries Regulation: Preparing for next year’s compliance requirements (with Circulor)

FAQs

  • When will the EUBR guidance be finalised and published?

    Following the Omnibus IV package proposed in May 2025, the guidelines were expected to be published in July 2026. However, they have not yet been published, and there is currently no confirmed publication date.

  • Do companies still need to be audited by a notified body by August 2027?

    Yes. Economic operators need to be third-party-verified by a notified audit latest by August 2027.

  • Are any national authorities close to appointing a notified body?

    No. The process for approving notified bodies, including specifications for how they are expected to conduct third-party verification, was proposed in the latest draft guidelines published in May 2026.

    We do not expect any notified bodies to be approved before the final guidelines and technical specifications are officially published. Approved notified bodies are listed on the European Commission’s NANDO website.

  • If reporting is only required every three years, will third-party verification by notified bodies also take place every three years?

    No. The frequency will depend on the final specifications for third-party verification. The latest draft proposal, published in May 2026, included annual third-party verification activities in line with ISO 17021.

  • What should we do if our battery suppliers are unwilling to share information about their supply chains?

    The regulation requires economic operators to provide information about the origin of in-scope raw materials and the ESG risks associated with their production and processing. These requirements will apply to economic operators in every EU Member State.

    Article 39 also requires battery cell and pack manufacturers to provide economic operators with the required information free of charge. Over time, and through collective leverage, suppliers are therefore likely to become more willing to share the information required for compliance if they wish to continue selling products into the EU market.

    However, the regulatory landscape is evolving quickly, with requirements that may differ or conflict across jurisdictions. Economic operators and their suppliers should monitor these developments closely and seek appropriate expert advice on how data can be shared to meet regulatory requirements while maintaining commercial relationships.

    Companies should also ensure that their information requests are proportionate. Suppliers may continue to resist requests that go beyond the information needed to conduct risk-based due diligence.

  • Are the due diligence requirements based on the materials used in the battery, regardless of where they are used?

    The due diligence requirements apply to the active battery materials only.

  • What happens if a company has only just started its due diligence activities by August 2027?

    Under the current requirements, companies must achieve third-party verification by a notified body by August 2027. Companies should therefore have the necessary management systems and processes in place before this date, ready for review by a notified body.

    The exception is the reporting requirement under Article 52, which is not due until August 2028 according to the latest draft guidelines published in May 2026.

  • Is a traceability tool mandatory for all suppliers and materials, or can companies take a risk-based approach?

    Companies must collect the minimum information specified in Article 49(2). Any traceability tool should focus on collecting these required data points without going significantly beyond them, as disproportionate requests may lead to supplier resistance.

  • What types of due diligence schemes are being assessed for official recognition?

    The process for recognising due diligence schemes under Article 53 is still being developed, and there is currently no confirmed timeline. Once the recognition process has been introduced, due diligence schemes will be able to decide whether to apply for EUBR recognition.

  • Are the due diligence requirements limited to Tier 1 suppliers, or do they apply across the whole value chain?

    The scope of supply chain due diligence covers the mining, trading and processing of in-scope raw materials, up to and including the production of cathode and anode active materials (CAM and AAM).

    Battery cell manufacturing and later stages, such as battery assembly, are not included in the due diligence scope for managing the risk categories listed in Annex X.2.

    However, the information required under Article 49(2), particularly points (c) and (f), must be collected across the entire supply chain, including the battery manufacturing stages.