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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.

Our main 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.

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.

Navigating the EU Batteries Regulation: Implications for US companies

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.