ISSUE 03JUNE 3, 2026EU INDUSTRIAL PROCUREMENT

Battery supply chain data requirements go live in 8 months — what your suppliers must be able to prove

THIS ISSUE COVERS / AU SOMMAIRE

  • EU Batteries Regulation: What Suppliers Must Prove (Articles 48–52)
  • EU Automotive OEM Inventory Overhang: 65–72 Days of Supply
  • CRMA Strategic Projects: 47 Approved — Minerals, Timelines, Next Steps
  • Procurement Staffing: CPO Hiring Surge Masks a Deeper Skills Gap
  • EU Steel: Domestic Price Premium Narrows Post Anti-Dumping Duties
  • Procurement Move: BASF shifts ammonia to Norwegian/Moroccan sources
  • Regulatory Clock: CRMA Permitting Deadlines Nov 2026–Mar 2027
THIS WEEK'S BRIEF / LE BRIEF DE LA SEMAINE

The EU Batteries Regulation's supply chain due diligence deadline is close enough that procurement teams with automotive, energy storage, or industrial battery exposure can no longer treat it as a planning item. This week we also break down which minerals and timelines the Critical Raw Materials Act is actually accelerating — because the CRMA strategic project list is more actionable than most briefings let on — and we cover what the current EU automotive inventory glut means for Q3 and Q4 purchasing decisions. Plus: why the CPO hiring surge is creating a skills crisis, not solving one.

SIGNAL ITEMS / SIGNAUX
01

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

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Signal Items #2–5

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