{"id":16552,"date":"2025-06-11T14:10:58","date_gmt":"2025-06-11T11:10:58","guid":{"rendered":"https:\/\/www.paristokierratys.fi\/blog\/2025\/06\/11\/batteryregulation-answers-from-the-webinar-proper-due-diligence-in-the-battery-supply-chain\/"},"modified":"2025-06-30T14:22:08","modified_gmt":"2025-06-30T11:22:08","slug":"batteryregulation-answers-from-the-webinar-proper-due-diligence-in-the-battery-supply-chain","status":"publish","type":"post","link":"https:\/\/www.paristokierratys.fi\/en\/blog\/2025\/06\/11\/batteryregulation-answers-from-the-webinar-proper-due-diligence-in-the-battery-supply-chain\/","title":{"rendered":"#BatteryRegulation: answers from the webinar \u2013 proper due diligence in the battery supply chain"},"content":{"rendered":"

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Due diligence in the battery supply chain \u2013 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.<\/strong><\/p>\n

The European Union\u2019s 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 Akkukierr\u00e4tys Pb Oy, which operate as battery producer organisations. The webinar attracted around 230 participants interested in these timely topics.<\/p>\n

CS3D requires companies to identify and respond to risks<\/h2>\n

Netta Sk\u00f6n, sustainability lawyer at Fondia Plc, presented the key requirements of the Corporate Sustainability Due Diligence Directive (CS3D). The directive currently applies to large companies \u2013 those with more than 1,000 employees and annual turnover exceeding \u20ac450 million \u2013 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.<\/p>\n

Information gathering is at the heart of the directive. According to Sk\u00f6n, a company must understand the risks related to its own operations and supply chain: \u201cIn the global economy, value chains are complex, but this makes data management and understanding of impacts even more critical.\u201d<\/p>\n

Battery regulation vs. CS3D: similarities and differences<\/h2>\n

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.<\/p>\n

Sk\u00f6n sees the overlapping regulations not as a problem but as an opportunity: \u201cIf a company integrates its DD process effectively, it can meet the requirements of both regulations with one system.\u201d<\/p>\n

Regulatory landscape changing \u2013 impacts of the Omnibus packages<\/h2>\n

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.<\/p>\n

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 \u20ac40 million turnover to those with \u20ac150 million in turnover. The turnover threshold applies to the company\u2019s entire revenue, not just the battery business.<\/p>\n

Johanna Routio, ministerial adviser from the Ministry of the Environment, stressed that the delay should not be seen as a transition period: \u201cCompanies should use the additional time to prepare and develop their processes.\u201d<\/p>\n

The Omnibus IV proposals can be commented on through the EU\u2019s Have Your Say<\/em> portal<\/a>. The points open for feedback concern, in particular, changes to the timeline and turnover thresholds.<\/p>\n

What does the Battery Regulation require in practice?<\/h2>\n

Kati Suomalainen, senior specialist at the Ministry of the Environment, presented the content of Chapter VII of the Battery Regulation, particularly Articles 49\u201353, 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 \u2013 and on managing social and environmental risks throughout the supply chain.<\/p>\n

Companies are required to:<\/p>\n