#BatteryRegulation: answers from the webinar – proper due diligence in the battery supply chain
Due diligence in the battery supply chain – what do the Battery Regulation and the Corporate Sustainability Due Diligence Directive (CS3D) require from companies? These questions were addressed in the fifth Battery Regulation webinar.
The European Union’s Battery Regulation and Corporate Sustainability Due Diligence Directive (CS3D) impose new types of obligations on companies to ensure responsibility throughout their supply chains. These topics were explored during the Battery Regulation webinar held on 3 June 2025, where experts shed light on the content and impact of the new regulations on business operations. The event was organised by Recser Oy and Akkukierrätys Pb Oy, which operate as battery producer organisations. The webinar attracted around 230 participants interested in these timely topics.
CS3D requires companies to identify and respond to risks
Netta Skön, sustainability lawyer at Fondia Plc, presented the key requirements of the Corporate Sustainability Due Diligence Directive (CS3D). The directive currently applies to large companies – those with more than 1,000 employees and annual turnover exceeding €450 million – and requires the implementation of a comprehensive due diligence (DD) process to identify, assess, prevent, or mitigate adverse human rights and environmental impacts throughout the value chain.
Information gathering is at the heart of the directive. According to Skön, a company must understand the risks related to its own operations and supply chain: “In the global economy, value chains are complex, but this makes data management and understanding of impacts even more critical.”
Battery regulation vs. CS3D: similarities and differences
Both the Battery Regulation and CS3D emphasize responsible business conduct and supply chain transparency. They share the goal of preventing environmental and human rights risks. However, they differ in nature: the Battery Regulation is directly applicable EU legislation, while CS3D is a directive that requires national transposition. Additionally, the Battery Regulation specifically targets the battery value chain, whereas CS3D applies across multiple industries.
Skön sees the overlapping regulations not as a problem but as an opportunity: “If a company integrates its DD process effectively, it can meet the requirements of both regulations with one system.”
Regulatory landscape changing – impacts of the Omnibus packages
EU sustainability legislation is undergoing reform through so-called Omnibus packages, which introduce multiple changes or clarifications across regulations simultaneously. Notably, several changes have been proposed to CS3D, and its application timeline has been postponed by two years, now set to take effect in 2028.
The Omnibus IV package, published in late May, also proposes changes to the DD obligations under the Battery Regulation: the entry into force may be delayed by two years, and the threshold for applicability could be raised from companies with €40 million turnover to those with €150 million in turnover. The turnover threshold applies to the company’s entire revenue, not just the battery business.
Johanna Routio, ministerial adviser from the Ministry of the Environment, stressed that the delay should not be seen as a transition period: “Companies should use the additional time to prepare and develop their processes.”
The Omnibus IV proposals can be commented on through the EU’s Have Your Say portal. The points open for feedback concern, in particular, changes to the timeline and turnover thresholds.
What does the Battery Regulation require in practice?
Kati Suomalainen, senior specialist at the Ministry of the Environment, presented the content of Chapter VII of the Battery Regulation, particularly Articles 49–53, as well as Article 93 of Chapter XIV. The DD obligations focus on the sourcing, processing, and trade of raw materials and secondary raw materials – and on managing social and environmental risks throughout the supply chain.
Companies are required to:
- Establish an operational policy and communicate it to suppliers and the public
- Ensure traceability through upstream chains
- Prepare a risk management plan and integrate it into business strategy
- Set up a grievance mechanism
- Undergo an audit conducted by a notified body
The proposed Omnibus changes are also expected to delay the publication of the Commission’s DD implementation guidelines until July 2026.
Sandvik’s experience: getting a head start through proactivity
The webinar concluded with a company case example from Sandvik Mining and Construction Oy. The company has proactively begun developing its due diligence process, focusing particularly on industrial batteries. Hinrich Kress described the project as requiring a group-level solution, close collaboration, and budgeting – with a single audit potentially costing up to €20,000.
Kress expressed concern about notified bodies becoming bottlenecks but remained optimistic about the future: “Legislators are behind schedule, but if we can demonstrate genuine efforts to comply, that will go a long way.”
Summary
It is time for companies to wake up to the responsibility requirements in their supply chains. Both the EU Battery Regulation and CS3D steer business toward more transparent and sustainable practices. Proactive preparation helps avoid last-minute rushes and potential sanctions – and can also provide a competitive advantage in a changing business environment.
Read our previous articles:
#BatteryRegulation: The Battery Passport is Coming – Are You Ready? – Paristokierrätys
This article is a part of the joint communications of the battery producer organisations Recser Oy and Akkukierrätys Pb Oy concerning the EU Batteries Regulation. You can also subscribe to our newsletter to receive the latest news on the subject.
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