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 from | 18 August 2025 |
|---|---|
| Threshold | Group net turnover of at least EUR 40 million |
| Materials | Cobalt, natural graphite, lithium, nickel and related chemical compounds |
| Verification | By a notified body, with periodic audits |
| Records | Kept for at least 10 years |
| Last verified | 2026-10-19 |
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.
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