The European Union has postponed the implementation time of due diligence

On May 21, 2025, the European Commission released a proposal related to battery due diligence under the new EU Battery Law. The key contents are as follows:
The battery due diligence obligation originally scheduled to be implemented on August 18, 2025 has been postponed by two years to August 18, 2027.
The battery due diligence guidelines will be released one year before the obligation takes effect, and are expected to be released on July 26, 2026.
3. The battery due diligence is adjusted to economic operators with a net turnover of no less than 150 million euros in the previous fiscal year.
4. The frequency of economic operators disclosing battery due diligence reports has been adjusted from once a year to once every three years.

The main reasons for this revision are:
1) The supply chain of battery raw materials is affected by changes in the geopolitical landscape and requires time to analyze and adjust the supply chain.
2) The battery due diligence policy needs to be reviewed by the announcement body. Currently, more time needs to be provided for the establishment of third-party certification bodies.
3) The plan for battery raw materials still needs to be further developed and implemented before it can pass the plan approval process of battery due diligence.
4) Affected by the adjustment of the Corporate Sustainability Due Diligence Directive (CSDDD).
5) To alleviate the burden on some enterprises and free up resources for growth and investment, the exemption scope was further extended to small mid-caps enterprises (SMCs), which are usually three times the size of small and medium-sized enterprises (SMEs).
MCM reminder:
Although the fulfillment time of the battery due diligence obligations has been postponed, the relevant enterprises still need to make preparations in advance to ensure that they meet the battery due diligence requirements and complete the review of the notified body by August 18, 2027.

Currently, MCM is collaborating with authoritative third-party institutions to conduct battery due diligence business. If you would like to know more, please feel free to contact us at any time!