Date note: Postponed from 2025-08-18 by Regulation (EU) 2025/1561
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Companies placing batteries on the EU market must run a due diligence system for raw materials such as cobalt, lithium, nickel and natural graphite: supply-chain policy, risk identification, third-party verification and public reporting. Companies with net turnover below €40M are exempt.
Larger battery manufacturers and importers (turnover €40M or more); smaller firms should expect information requests from customers in scope.
Sizes: medium, large · Sectors: Hardware / electronics, Manufacturing, Energy, Transport / logistics · Applies if: We sell products with batteries; We import goods into the EU
If your turnover is €40M or above, adopt a battery raw-material due diligence policy aligned with OECD guidance, map your cell and material suppliers, and arrange third-party verification. Smaller suppliers: prepare to answer customer due diligence questionnaires.
Last verified 7 September 2026. Informational only, not legal advice.
Manufacturers and importers of EV batteries, light-means-of-transport batteries (e-bikes, scooters) and industrial batteries above 2 kWh, and of products built with them (e-bikes, energy-storage systems, forklifts, EVs); distributors must check the QR code is present. Ordinary consumer batteries (e.g. AA/AAA, phone or laptop batteries) and products containing only those are out of scope.