Battery Due Diligence Updates 2025
- Gokulakrishnan Kalaivanane
- 4 days ago
- 4 min read
The EU Battery Regulation (EU) 2023/1542 establishes due diligence responsibilities for economic operators who place batteries on the EU market, particularly in terms of raw material sourcing, processing, and transactions, including cobalt, lithium, nickel, and natural graphite. These obligations, as outlined in Chapter VII of the regulation, were initially scheduled to take effect on August 18, 2025, with the Commission providing supporting guidelines by February 18, 2025. However, two legislative proposals published recently, the COM(2025) 258 final and COM(2025) 501 final, introduce targeted amendments to refine both the timing and scope of these obligations.
Timeline change
The COM(2025) 258 final proposes two key amendments to Article 48(1) of Regulation 2023/1542:
Application of due diligence requirements: from 18 August 2025 to 18 August 2027
Extension of the deadline for publishing due diligence guidelines: from 18 February 2025 to 26 July 2026
Though limited in textual scope, these changes have significant structural implications, allowing Member States to designate notifying authorities, develop and accredit notified bodies, and formalise due diligence schemes under Article 53, all of which are required for the regulation to be credible and uniformly enforced.
Why the delay?
Member states and economic operators were not yet operationally prepared to meet every aspect of due diligence requirements. The Commission highlighted a few implementation hurdles:
Fewer than half of the EU Member States had designated notifying authorities to oversee notified bodies.
The European Cooperation for Accreditation had not yet established conformity evaluation benchmarks for due diligence schemes.
No due diligence schemes had been legally recognised under Article 53, leaving operators with no clear compliance path.
The overlap with the newly approved Corporate Sustainability Due Diligence Directive (CSDDD) raised legal uncertainty.
The Commission concluded that maintaining the original timeline could undermine the regulation’s effectiveness and credibility, justifying a targeted extension.
Introducing Small Mid-Cap (SMC) exemptions
The proposed amendment, COM(2025) 501 final, introduces a new category of economic operators called Small Mid-Cap Companies (SMCs), which are defined as organisations with an annual net turnover of less than €150 million. Under the amendment, these companies would also be exempt from due diligence procedures, expanding the exemption beyond the current threshold for SMEs, which only comprises entities with a revenue of less than €40 million. While larger than SMEs, SMCs still have limited compliance capacity, and the regulation exempts them from the most onerous responsibilities under Chapter VII, such as third-party verification and risk mitigation requirements for supply chain due diligence.
Companies with a turnover of €150 million or more are subject to all due diligence requirements.
The Commission retains the authority to impose simplified or periodic reporting obligations on SMCs in accordance with the concept of proportionality. This calibrated strategy promotes compliance and involvement among mid-sized businesses while minimising undue administrative obligations.
What does this mean for economic operators?
The proposed amendments would provide regulated entities in the battery value chain more operational clarity and transitional flexibility. The postponement of due diligence obligations until 2027 should not be construed as a dilution of regulatory intent; rather, it is a strategic adjustment aimed at allowing economic operators to develop strong compliance frameworks, participate in proper industry schemes, and ensure readiness for the complete and effective implementation of upcoming due diligence standards.
For companies with a turnover ≥ €150 million, the obligations remain fully intact. These operators must:
Establish and document robust supply chain mapping systems
Collaborate with due diligence scheme providers
Prepare for independent verification by accredited notified bodies
For newly exempted SMCs, this period presents a strategic opportunity to voluntarily align with best practices, ensuring readiness in case of future regulatory expansion or market-driven expectations.
Streamlining due diligence under EU Battery Regulation with CSDDD
The Commission emphasises the importance of coordinating sector-specific and horizontal regulations. The Corporate Sustainability Due Diligence Directive (CSDDD), which was adopted in 2024, establishes broader due diligence responsibilities for environmental, human rights, and governance issues. Although the Battery Regulation is more technically strict and focuses on crucial raw materials, both frameworks require corporations to establish risk-based procedures and mitigation plans throughout global supply chains. Aligning the publication of guidelines under both instruments promotes coherence, avoids duplication, and allows for more efficient compliance.
Strategic pause for effective compliance
These proposed laws give economic operators the necessary time and clarity to prepare for the EU Battery Regulation's high sustainability targets. By extending the due diligence application deadline to 2027 and expressly exempting small mid-cap enterprises with a revenue of less than €150 million, the EU ensures that compliance is not only attainable but also proportional and effective. This does not represent a retreat, but rather a deliberate and strategic pause intended to allow enterprises, competent authorities, and supporting systems to mature in alignment with the regulation’s objectives.
At Battery Associates (B.A), we offer comprehensive compliance solutions for European battery regulations, guiding you through the industry's evolving landscape. Our expert team offers tailored solutions and insights to navigate these requirements seamlessly. Reach out to us for detailed support and information on meeting compliance standards.
About the Author

Research Analyst - Battery Associates
Gokul is currently a Research Analyst at Battery Associates. He holds a master's degree in energy engineering from Politecnico di Milano and a bachelor's degree in mechanical engineering. His expertise lies in power generation, renewable energy, and energy storage. Gokul is passionate about battery technology and its ability to fulfill the changing needs of the energy sector. He is particularly interested in battery energy storage systems (BESS), Electric vehicles (EV), and promoting a circular economy throughout the battery value chain.
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