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Alex Graf

Senior Consultant

Kumi Newsletter June 2024

As you may know, the European Commission has assigned Kumi to draft the Implementation Guidelines for due diligence in the Regulation. Additionally, we are developing the methodology and process for recognising due diligence schemes under the Regulation.

There is a tight turnaround between now and August 2025 when the requirements must be met, but the attention to the due diligence obligations is growing amongst companies. We fully support this trend and encourage everyone in the battery industry – regardless of their supply chain stage – to follow and understand their specific role and responsibility.

There is still significant uncertainty about how to comply with the different requirements of the regulations. Given the lack of current guidance, this is no surprise. However, there is the risk of misinterpretation based on common understandings and/or practices, which are not necessarily in line with international due diligence frameworks or current good practices. For example, the use of due diligence schemes and supplier audits – as important as these tools can be – should not be relied on as a default solution. Instead, they need to be integrated into a risk-based approach that is both scalable and impactful. Let’s remember, the Regulation requires companies to own their responsibility for due diligence!

If you want to understand the right mindset and approach to complying with EU mandatory due diligence, have a look at our insights and get in touch – we are happy to have a chat.

Alex Graf
Senior Consultant

The key developments this month:
1. BASF decides against investment in nickel-cobalt refining complex in Indonesia
“We will not execute the nickel-cobalt refining project in Weda Bay. Since the inception of the project, the global nickel market has changed significantly. In particular, the supply options have evolved and with that BASF’s availability of battery grade nickel.
2. Yearly Update -Transition Minerals Tracker: 2024 Global Analysis
Indigenous Peoples disproportionately bear the brunt of the harmful impacts of transition minerals mining – with 61 allegations (10%) across all years impacting their right.
3. On the trail of African gold – Swissaid
Each year, between 321 and 474 tonnes of artisanal gold are produced in Africa without being declared. This equates to a value of between $24 and $35 billion and between 72 and 80% of the total production of artisanally mined African gold.
4. ‘Conflict Minerals’ in Congo: Do Traceability Schemes Work? 
Section 1502 required companies to conduct due diligence checks on their supply chain to disclose their use of minerals originating from Congo and neighboring countries and to determine whether those minerals may have benefited armed groups.

Kumi appointed to Battery Regulation

Kumi appointed to develop the Due Diligence Guidelines for the EU Battery Regulation

Kumi has been appointed by the European Commission to help implement the due diligence provisions of the EU Battery Regulation.

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Alex Graf

Senior Consultant