Battery Due Diligence Deadline Postponed—But the Clock Is Still Ticking

On 21 May 2025, the European Commission proposed a two-year delay to the battery due diligence obligations under Regulation (EU) 2023/1542—shifting the deadline from August 2025 to 18 August 2027. While this extension provides more time to prepare, it also raises critical questions for battery stakeholders:

• What does this mean for your compliance roadmap?
• How does this affect ongoing battery traceability, passporting, and sustainability investments?
• And what can you do now to turn uncertainty into strategic advantage?

This briefing outlines the implications of the proposed delay, the concerns raised by thought leaders across the sector, and how NMi can support your organization during this critical transitional window.

What’s Changing—and Why It Matters

The proposed amendments aim to ease regulatory pressure under the guise of “Single Market simplification.” Key changes include:

• Two-year delay to battery due diligence (new deadline: 18 August 2027)
• Reporting frequency reduced from annual to once every three years (starting 2028)
• New exemptions for “Small Mid-Cap” (SMC) companies (≤750 employees or <€150M turnover)

While framed as business-friendly, these changes are controversial. Some stakeholders view them as a threat to Europe’s environmental credibility and industrial competitiveness.

“Delaying and reducing the scope of the Battery Regulation risks undermining the EU’s climate and industrial leadership.”
— Robin Roels, EU Raw Materials Coalition¹

What We’re Hearing Across the Sector

“Delays risk undoing the significant progress made and damage the competitiveness of European companies leading in supply chain transparency.”
— Emily Ritchey, Transport & Environment¹

“Another confusing signal from the Commission… it risks making the EU look like an amateur regulator.”
— Richard Gardiner, World Benchmarking Alliance¹

“Size should not define responsibility. All firms have a role in ensuring a human rights–compliant green transition.”
— Jacob Bogart, Perseus Strategies¹

Insight from NMi

“This delay must not be misread as an excuse to slow down. On the contrary, it’s a unique opportunity to get systems right—before enforcement ramps up. The best time to invest in supply chain transparency, digital product passports, and audit readiness is now.”
— Dr. Valentina D’Amelio, Innovations Manager Electrification, NMi Group

At NMi, we work closely with emerging and established players across the battery ecosystem. We understand that regulatory uncertainty can stall progress and that early adopters will shape the standard, not just meet it.

Practical Steps to Strengthen Your Compliance Position

During this transitional period, NMi offers tailored services to help you stay ahead:

• Supply Chain Mapping & Risk Assessment
  Map material origins and social/environmental risks—aligned with CSDDD and Battery Regulation expectations.
• Due Diligence Framework Development
  Design internal systems for documentation, reporting, and corrective actions—futureproofed for upcoming guidelines.
• Audit Preparation & Pre-Assessment
  Simulate third-party reviews to prepare for Notified Body requirements, even before formal designations.
• Integrated Compliance Strategy
  Ensure your due diligence aligns with CE marking, battery passporting, carbon footprint calculations, and sustainability targets.

Key Takeaways

1.   The delay is proposed but has not yet been adopted. Monitor developments closely.
2.   The regulation’s core intent remains intact: enforce ethical, transparent, and circular battery value chains.
3.   Many companies have already invested heavily in readiness—don’t lose momentum.
4.   SMCs may be exempted, but “compliance capability” is not a reliable excuse for inaction.
5.   Supply chain transparency is a competitive advantage—especially as the energy transition accelerates.

FAQs

Q: Does this mean we can delay our compliance planning?

A: No. The implementation may be delayed, but requirements remain unchanged. The companies that start now will avoid costly scrambles later.

Q: What about Notified Bodies?

A: Designation is still underway, but NMi can help you prepare with simulated assessments and gap analysis.

Q: Are we exempt as a Small Mid-Cap?

A: Possibly, but even exempt firms benefit from voluntary compliance—especially when operating across borders or supplying regulated OEMs.

Next Steps

If your organization touches the battery value chain—whether you’re a manufacturer, integrator, importer, or recycler—this is the time to review your readiness plan.

Contact us to learn more or schedule time with one of our Battery Regulations Experts.