When the EU adopted its landmark Battery Regulation, due diligence requirements were meant to take effect in August 2025. Now, companies have been granted a two-year reprieve according to the update on the EU Commission's website. The main goal of the postponement is to give battery producers and exporters more time to prepare. The obligations will not apply until August 2027.
The Due Diligence obligations remain one of the most complex regulatory challenges facing companies in the energy and mobility sectors. With new thresholds, reporting rules, and expectations for transparency, businesses cannot afford to wait until the last minute. This article explores due diligence obligations, what the postponement means, why it happened, what obligations remain, and how companies can use the extra time wisely.
Why Was Due Diligence Postponed?
The postponement was confirmed in July 2025 as part of the Omnibus 4 package, shifting the enforcement of due diligence obligations from 18 August 2025 to 18 August 2027. Several reasons explain the delay:
Unprecedented complexity
Mapping global supply chains, many of which involve multiple tiers and opaque sourcing routes proved far more challenging than anticipated. Companies rarely have visibility beyond tier one or two suppliers, making it difficult to identify upstream miners or refiners.
Alignment with wider EU legislation
Due diligence is not limited to batteries. The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) and other regulations are introducing overlapping obligations. The postponement helps synchronize these frameworks to avoid conflicting requirements.
Feedback from industry
Businesses lobbied for more time, citing short implementation windows, high compliance costs, and lack of clarity.
What Are the Key Due Diligence Obligations?
Once in force, the obligations will apply to economic operators placing batteries on the EU market who exceed the updated turnover threshold of €150 million (up from the earlier €40 million).
Affected companies must:
- Develop a battery due diligence policy aligned with ESG principles and international standards listed in Annex 10 of the regulation.
- Implement a chain of custody or traceability system capable of tracking lithium, nickel, cobalt, and natural graphite through the supply chain.
- Conduct regular risk assessments on suppliers and sourcing regions.
- Introduce grievance mechanisms to address human rights or environmental concerns.
- Publicly report on due diligence performance every three years (instead of annually, as originally planned).
These measures are designed to provide full visibility into supply chains, promote ethical sourcing, and strengthen accountability for environmental and human rights impacts.
The Biggest Challenge for Compliance
Even before the postponement, companies reported several obstacles such as data sensitivity, low cooperation – limited collaboration across supply chain tiers, a lack of EU guidance, absence of accredited verifiers, costs and a need for qualified resources. These issues highlight why the industry pushed for more time.
However, to conclude, the biggest challenge lies in supply chain mapping.
- Materials often cross multiple borders, changing hands several times.
- Information is fragmented, sensitive, and not always shared by upstream suppliers.
- Companies rarely have visibility beyond tier two suppliers, making it difficult to identify the original mines or refiners.
Only a handful of vertically integrated companies, those controlling everything from raw material extraction to end-product assembly can fully map their supply chains today. For most, the task is daunting and will require systematic data collection, supplier collaboration, and digital traceability tools.
Where Should Companies Start?
If you haven’t yet started, it’s advisable to start as soon as possible. Compliance requires years of preparation, not months. Companies should:
- Start small – pilot mapping exercises on one product line or battery model.
- Engage suppliers early – build trust, offer incentives, and create awareness.
- Digitize data collection – invest in traceability tools now to avoid future bottlenecks.
- Phase the approach – gradually expand coverage to the full portfolio.
- Plan for 2027 as a hard deadline – companies must be compliant by then, not starting.
The Road Ahead
The EU’s decision to postpone enforcement is not a sign of retreat but a recognition of reality. Supply chain due diligence is difficult, costly, and resource-intensive, yet essential for building ethical, sustainable industries.
The postponement offers companies two precious years - time to map supply chains, build systems, and engage suppliers. Those who use this period strategically will not only meet regulatory requirements but also gain a competitive edge in a market increasingly driven by transparency, accountability, and sustainability.
The clock is still ticking. August 2027 is the enforcement date, not the starting point. Companies that wait risk scrambling to comply, damaging their reputation and losing market access. Those that act now will be both ready and better positioned to thrive in a world where due diligence is no longer optional but a baseline expectation.
Minespider’s Digital Battery Passport helps you map supply chains, collect supplier data, and meet due diligence requirements long before the 2027 deadline. Get started today and future-proof your compliance.
