European UnionDelayed
Corporate Sustainability Due Diligence Directive
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
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Mandatory raw material supply chain due diligence for batteries covering cobalt, lithium, nickel and natural graphite.
Due diligence postponed to 18 August 2027 by Regulation 2025/1561; guidelines due July 2026.
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.
Regulation began applying generally, with obligations phased over subsequent years.
Regulation (EU) 2025/1561 postponed the due diligence obligations by two years.
Commission due diligence guidelines due under the revised calendar.
Battery passport requirements apply to covered battery categories.
Supply chain due diligence obligations apply to economic operators.
Changelog
Entry updated after the postponement of the due diligence chapter was confirmed.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Sources
Same jurisdiction
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
Read →Omnibus narrowed scope to 1,000 employees from FY2027; first wave reporting continues with opt-outs.
Read →Second postponement published one week before application; large operators now start on 30 December 2026.
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