WEBINAR: Beyond the EU Batteries Regulation: Tackling global regulatory complexity with supply chain due diligence
The global regulatory landscape for supply chain due diligence is becoming increasingly complex. Uncertainty following recent announcements on the EU’s Omnibus exemplifies this, leaving some businesses without the much-needed clarity on compliance requirements, enforcement mechanisms, and how regulations will interact.
Building on our previous deep dive into due diligence under the EU Batteries Regulation (EUBR), this webinar explored the wider regulatory landscape that should shape and inform your global supply chain due diligence strategy, alongside the EUBR. This includes Europe’s Corporate Sustainability Due Diligence Directive (CSDDD), Corporate Sustainability Reporting Directive (CSRD), as well as various market import and trade restrictions.
We explored the differences but also the common threads that link the responsible sourcing and due diligence requirements set out by these regulations. We discussed how companies can implement due diligence processes that provide confidence that compliance requirements are being met, and supply chain risks effectively addressed.
This webinar on the EU Batteries Regulation covered:
- Future proofing your compliance strategy: How the EU Batteries Regulation fits within the wider regulatory landscape and what this means for the design and implementation of supply chain due diligence frameworks. Essential digital tools for creating greater transparency and providing confidence in supply chain controls.
- Why collaboration across the supply chain is critical: While batteries are the first to be subject to the most stringent due diligence requirements, they won’t be the last. We’ll explore why proving provenance is now a shared responsibility.
- How to approach uncertainty and ambiguity: With the EU Omnibus Directive creating additional regulatory uncertainty, how can you structure due diligence efforts to adapt to shifting compliance expectations in the face of ambiguity?
- Thinking beyond regulatory compliance: How effective due diligence reduces operational risk, enhances efficiency, strengthens brand trust and creates a competitive advantage across increasingly complex markets.
- Lessons from peers: Hear from industry peers on how they are aligning with multiple regulations across different jurisdictions, while maintaining operational flexibility.
Join speakers from Kumi and Circulor, alongside Senior Human Rights Expert, Charline Daelman of Panasonic as we help you cut through complexity and develop a smarter, more strategic approach to your global supply chain due diligence.
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Frequently asked questions
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The EU’s Omnibus has indicated a quite significant potential change for CSDDD. What impact will this have on the EUBR’s due diligence requirements?
The EUBR is currently not included in the omnibus and although future simplification packages planned by the Commission may do so, no substantial changes are expected as of now. Despite any uncertainties, we strongly advise companies to continue preparation for due diligence requirements under current EU legislation (especially EUBR, CSDDD). In particular, one should follow international frameworks such as the OECD Due Diligence Frameworks and UNGPs that underpin all of the current EU due diligence legislation.
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When will the due diligence guidelines be published?
Although the EUBR is not part of the Omnibus negotiations and simplification packages, while negotiations are ongoing, there is currently no confirmed timeline for the publication of the EUBR guidance. Kumi is in continual dialogue with the commission, however, so do watch our posts on the topic, as we will communicate any updates once we receive them.
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Can we expect the 18 Aug 2025 deadline for due diligence compliance to be pushed out given the delay from the EU commission?
The EUBR due diligence requirements apply from August 18, 2025, no changes to the deadline are known. However, it is likely that notified bodies will not be available in time, in which case third party verification would be postponed until they are in place. The remaining due diligence obligations are still due by August which the exception of public reporting, which is expected to be in force only by August 2026. Please note that there are further simplification packages in the pipeline which might include postponements of deadlines, but nothing is confirmed at this point.
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Are there notified bodies confirmed?
No, no notified bodies are currently confirmed, meaning that third-party verification cannot be carried out currently. Therefore, while this requirement does not need to be fulfilled, all other requirements will still be in effect by August, and the first public report is expected to be due by August 2026. The EC and Member States are still setting up the process for approving notified bodies. As of now, notified bodies are not expected to be approved before August 2025, which means that this requirement will be enforced only once available. We strongly suggest companies continue preparing due diligence requirements rather than waiting for the notification of bodies. Adequate implementation requires sufficient lead time, and the remaining due diligence requirements apply from August 2025 regarding the existence of notified bodies. A list of all notified bodies for all regulations can be checked, though presently, there are none for the EUBR.
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Does third-party verification apply only to the due diligence process or does each annual report need to be verified by a third party?
The notified body will be responsible for periodically verifying an economic operator’s implementation of all due diligence requirements listed in Articles 49, 50 and 52, including the performance of implementation, reporting, etc.
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Can the reporting obligation under the EUBR be included in other annual, non-financial reporting by the company?
The reporting obligations under the EUBR can be combined with other company reporting obligations, e.g., CSRD. It is important to ensure that the full scope of requirements, risks, raw materials, supply chain stages, etc., required under the EUBR is covered.
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How important is the role of second life? How will this be enabled?
The role of 2nd life batteries is very important in decabonizing, diversifying power markets and securing critical minerals. The supply chain data, coupled with data in the battery passport, will enable faster and more efficient pathways to second life and ultimately recycling.
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What do companies do when upstream suppliers refuse or are unable to provide relevant information?
From our experience, collaborating with a neutral third-party traceability provider may support economic operators in engaging with their suppliers. Circulor’s established network of battery value chain participants creates efficiencies for new customers. In principle, we recommend collaboration with suppliers to foster understanding regarding the purpose and need of supply chain transparency, including data required under the EUBR. In cases of continued non-cooperation without significant improvement, economic operators should consider long-term business strategies, including the potential suspension or termination of business relationships.
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How can we design and implement robust confidentiality protocols that enable effective data sharing across the battery supply chain while ensuring that proprietary information and trade secrets are fully protected and competitive positioning is maintained?
The definition of business confidentiality and confidential data varies among companies and across different national jurisdictions. Consequently, a one-size-fits-all approach is not feasible. By nature, there is a trade-off between transparency and confidentiality; however, specific mechanisms can mitigate this tension. For example, economic operators do not require comprehensive access to all information from the start, nor do they need access to all documentation required to verify the chain of custody information. For instance, neutral third parties can assess, verify, and confirm data validity without disclosing confidential information to economic operators. How much information needs to be disclosed to the economic operator depends on the risk profile of a supplier and its supply chain, as well as the ability to give assurances that risks are managed appropriately. Ultimately, it is the economic operator who has to decide whether the provided information is sufficient since it bears the responsibility under the law, which cannot be shifted.
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How deep should the companies go in their supply chains and where are the key risks?
The EU Battery Regulation states that this must be back to source for both primary and secondary materials, so either the mine site or waste source into recycling facilities. This is to ensure risks in the upstream are identified, managed and mitigated. The materials in scope of the EUBR due diligence requirements are cobalt, lithium, nickel and natural graphite given they’re the most common and high-risk materials in batteries.
