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A Comprehensive Analysis of Due Diligence Obligations Under the EU Battery Regulation (EU) 2023/1542
The revised “Battery Regulation (EU) 2023/1542,” published in the Official Journal of the European Union (OJ), aims to ensure the sustainability, efficiency, and safety of batteries placed on the EU market throughout their entire lifecycle, promote the recycling and reuse of battery materials, and advance the circular economy. In particular, due diligence obligations—a key component of this regulation—impose clear and stringent requirements on economic operators, who must comply with these obligations starting August 18, 2025.
Specific Details of the Due Diligence Obligations
The due diligence obligations under the Battery Regulation (EU) 2023/1542 apply to all economic operators placing batteries on the market or putting them into service, including but not limited to battery manufacturers, importers, and distributors. However, small and medium-sized enterprises (SMEs) may be exempt from certain requirements. The Regulation covers a wide range of battery types, including portable batteries, automotive batteries, electric vehicle batteries, industrial batteries, and batteries used for energy storage, with the exception of batteries used for military, aerospace, and nuclear applications.
(1) Develop and implement a due diligence policy: Effective August 18, 2025, relevant economic operators must develop and implement a battery due diligence policy. This policy should align with international standards, such as relevant OECD guidelines and the United Nations Guiding Principles on Business and Human Rights, to ensure that environmental and social factors—particularly human rights, labor rights, and environmental impacts—are fully considered at every stage of the battery supply chain.
(2) Identify and assess risks: Economic operators must comprehensively identify and assess the social and environmental risks that may arise during the procurement, processing, and trading of battery raw materials. For example, regarding critical raw materials such as lithium, cobalt, nickel, and natural graphite—which often originate from regions where human rights issues or environmental degradation risks exist—companies must pay particular attention to the risks associated with the extraction, trading, and processing of raw materials in these regions.
(3) Establishing a Grievance Mechanism: Companies must establish effective grievance procedures that allow employees, communities, and other stakeholders to report human rights violations or adverse impacts within the supply chain. At the same time, they must actively communicate and collaborate with civil society organizations, local governments, and affected communities to jointly resolve issues.
(4) Regular Reviews and Reporting: Economic operators must conduct annual reviews of their due diligence methodologies and publish the results of these reviews. In addition, regulations require third-party audits to verify the effectiveness of due diligence methodologies and ensure compliance with regulatory requirements. Audit results must be made public to enhance market transparency and trust.
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