Packaging, WEEE and batteries · 18 August 2025

EU battery due diligence

Operators with group turnover of at least EUR 40 million need a verified battery due diligence policy from 18 August 2025.

Key facts

Applies from18 August 2025
ThresholdGroup net turnover of at least EUR 40 million
MaterialsCobalt, natural graphite, lithium, nickel and related chemical compounds
VerificationBy a notified body, with periodic audits
RecordsKept for at least 10 years
Last verified2026-10-19

The threshold is narrow, the rest is not

Chapter VII does not apply to operators below EUR 40 million net turnover in the financial year before last, unless they are part of a group above that limit on a consolidated basis. That is a due-diligence exemption, not an exemption from registration, labelling or collection.

For operators above the threshold, the policy must cover the raw materials and risk categories in Annex X, be communicated to suppliers and the public, and be verified by a notified body with periodic audits.

What a policy has to contain

The management system needs top-management responsibility, supply-chain controls and traceability, a grievance mechanism and records kept for at least 10 years. Risk management includes identifying, assessing and responding to adverse impacts, then reporting the findings.

Third-party verification is not a one-off certificate. The notified body audits the policy periodically, and the operator has to keep the audit report with the compliance file.

Frequently asked questions

Does due diligence apply to every seller of battery products?

No. It applies to economic operators at or above EUR 40 million group net turnover. Smaller operators still have registration, labelling, collection and other producer duties.

Which raw materials are covered?

Cobalt, natural graphite, lithium, nickel and chemical compounds based on those materials, together with the social and environmental risk categories listed in Annex X.

Tell me when the rules change

De minimis thresholds, import tax rates and marketplace fee schedules move more often than most price lists. Leave an address and we will send a short note when one of the tracked markets changes.

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