EU Batteries Regulation: What Suppliers Must Now Be Able to Prove
Articles 48–52 of EU Regulation 2023/1542 require that battery manufacturers and importers selling into the EU establish and operate supply chain due diligence policies covering cobalt, lithium, natural graphite, and nickel sourcing — including mapping to mine-of-origin level, risk assessments for conflict-affected areas, and third-party audit evidence. The carbon footprint declaration requirement (Article 7) for EV and industrial batteries above 2 kWh is enforceable from February 18, 2027; the battery passport (Article 77) for EV batteries follows from February 2027 as well.
Critically, 'battery manufacturer' under the regulation includes OEM buyers who contract manufacture — so procurement teams that toll-manufacture or co-develop battery packs are directly in scope, not just battery cell suppliers.
Source / Source: EU Regulation 2023/1542 (Batteries Regulation), Articles 7, 48–52, 77; European Commission FAQ on Batteries Regulation implementation, May 2026