Position Paper
18 July 2025

Battery value chain industry associations answer to the consultation on postponement of the battery due diligence obligations under the Batteries Regulation

EUROBAT, together with RECHARGE, the voice of the advanced rechargeable and lithium batteries value chain in Europe, and Eurometaux, the voice of non-ferrous metals producers and recyclers in Europe, would like to support to the European Commission proposal for a regulation postponing the due diligence obligations under the Batteries Regulation and contribute with some further recommendations.

To ensure a coherent, effective, and enforceable due diligence framework for the battery sector, we recommend the following:

1. Alignment of due diligence rules across the EU Battery Regulation, Corporate Sustainability Due Diligence Directive (CS3D) and Corporate Sustainability Reporting Directive (CSRD) files.

2. Swift publication of the Battery Due Diligence Guidelines giving economic operators sufficient time to adapt to the future obligations.

3. Timely establishment of the national verification bodies.‎