European Union Delayed
Corporate Sustainability Due Diligence Directive
Omnibus negotiations settled a narrowed scope; member state transposition now runs to July 2027.
Read →The tracker · European Union
Mandatory raw material supply chain due diligence for batteries covering cobalt, lithium, nickel and natural graphite.
Battery supply chain due diligence obligations postponed to August 2027 under the simplification omnibus.
In plain language
The Batteries Regulation includes a due diligence chapter modelled on the OECD minerals guidance, requiring battery producers to establish management systems, identify and mitigate risks in cobalt, lithium, nickel and natural graphite supply chains, and have their policies verified by notified bodies.
The 2025 simplification omnibus postponed the due diligence obligations to August 2027 and adjusted thresholds, but the direction of travel is unchanged: mineral supply chains feeding the EU battery market will need documented, audited due diligence reaching mine level.
Obligations
Producers must adopt and communicate a due diligence policy for the four covered raw materials, aligned with OECD guidance.
Due diligence policies require verification by a notified body, with periodic reassessment.
Annual public reports on due diligence findings and mitigation are required.
Timeline
Regulation entered into force.
Omnibus package postponed the due diligence chapter and adjusted scope thresholds.
Revised application date for supply chain due diligence obligations.
Changelog
Entry updated after the postponement of the due diligence chapter was confirmed.
Sources
Same jurisdiction
Omnibus negotiations settled a narrowed scope; member state transposition now runs to July 2027.
Read →Omnibus lifted employee thresholds and delayed later reporting waves by two years.
Read →Application began for large operators on 30 December 2025; SME obligations follow on 30 June 2026.
Read →