Human rights and environmental due diligence in EU Battery Regulation 2. What are the due diligence requirements for battery businesses in the European market?

Zeroboard Inc.
Taku Nozoko, General Manager of the Solutions Development Department, Sales Division

The EU Battery Regulation , which will come into effect on August 18, 2025, will require businesses selling and using batteries in the European market to implement human rights and environmental due diligence (DD). This column summarizes the DD requirements that battery businesses should understand and comply with in practice, based on Chapter 7 of the EU Battery Regulation, which specifies the DD requirements overall, and Annex X, which defines the raw materials that should be subject to evaluation and the risk Category(environmental and human rights) that should be evaluated.

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Below is a summary of the column, available for download.

1. Businesses that qualify for DD

This chapter explains the requirements for businesses that are subject to human rights and environmental due diligence under the EU Battery Regulation . It clarifies which companies are subject to the regulation based on their net sales in the previous fiscal year and the sales and use patterns of batteries in the European market. In particular, it highlights important points to note regarding the fact that all battery Category will be subject to the due diligence from August 18, 2025.

2. Supply chain and risk items subject to reporting in DD

This chapter outlines the scope of supply chains that are subject to DD reporting in accordance with the EU Battery Regulation, as well as the social and environmental risks involved. It also explains the background to the need to identify risks going back to raw material procurement and why ensuring supply chain transparency is so important.

3. How to proceed with human rights and environmental due diligence

This chapter introduces the basic steps that companies should take when carrying out human rights and environmental due diligence in practice, based on OECD guidance, etc. It provides an overview of the concepts of "initial investigation" and "detailed investigation" in risk assessment, and the level of investigation required at each stage.

4. Information that is required and recommended to be shared across the supply chain

This chapter categorizes the information that needs to be shared across the supply chain in order to proceed with due diligence, categorizing it into "essential information" and "recommended information." It also provides perspectives for considering the extent to which information sharing is practical, while touching on the fact that the level of granularity required differs at each investigation stage.

5. Possible information sharing between businesses

This chapter explains how to promote information sharing within the supply chain based on the EU Battery Regulation. It outlines the system that economic operators should use to collect information, depending on whether or not suppliers are conducting their own due diligence.

6. Guaranteeing trade secrets in data sharing

This chapter deals with the practical Issue of balancing data integration, which is essential for DD compliance, with the protection of trade secrets. It explains what information is considered important in DD compliance and how to ensure transparency while maintaining confidentiality.

7. Conclusion

In the final chapter, we will summarize what preparations companies should make as the enforcement of the EU Battery Regulation approaches. We will also introduce our consulting Service that support DD compliance, as well as the latest information on our collaboration platform, such as the "Supplier Survey Function" and "Dataseed SAQ Self-Assessment Questionnaire (a cloud Service that streamlines the collection and management of supplier surveys)" that are designed with supply chain compliance in mind.

Human rights and environmental due diligence measures based on the EU Battery Regulation are already moving from the consideration stage to the implementation stage.

If you are considering your company's response policy, please download the full text and read it.

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*1)Source: EU Battery Regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1542

*2)Source: OECD Guidance: https://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-RBC-Japanese.pdf

*3)Source: "Business and Human Rights" Response, detailed version: https://www.moj.go.jp/content/001417137.pdf

*4)Source: "Published initiatives" website: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives_en?text=battery