The European Union continues to refine the regulatory framework supporting sustainable and responsibly sourced batteries. One of the latest developments is Commission Delegated Regulation (EU) 2025/1561, which supplements the Batteries Regulation (EU) 2023/1542 by establishing detailed rules for battery due diligence policies, management systems, risk management, third-party verification and public disclosure.
While Regulation (EU) 2023/1542 introduced the requirement for economic operators to establish battery due diligence policies, the delegated regulation provides much greater clarity on how those obligations should be implemented in practice. For organisations preparing Digital Battery Passports, these updates reinforce the importance of collecting, managing and sharing reliable supply chain information throughout a battery's lifecycle.
As the mandatory Battery Passport deadline of 18 February 2027 approaches, understanding these due diligence requirements is becoming increasingly important for manufacturers, importers and other economic operators placing batteries on the EU market.
What Does Regulation (EU) 2025/1561 Introduce?
The delegated regulation provides detailed implementation rules for the due diligence obligations established under Chapter VII of the Batteries Regulation.
Rather than creating an entirely new compliance framework, it explains how organisations should develop and maintain effective due diligence systems covering the sourcing of raw materials used in batteries, particularly where there are risks relating to human rights, labour rights, environmental protection and responsible business conduct.
The Regulation sets out requirements in several key areas, including:
- Battery due diligence policies
- Management systems and internal governance
- Risk identification and assessment
- Risk prevention and mitigation measures
- Independent third-party verification
- Public reporting and transparency
These provisions are closely aligned with internationally recognised responsible sourcing principles, including the OECD Due Diligence Guidance for Responsible Business Conduct and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, both of which are referenced throughout the EU framework.
Why Does This Matter For Battery Passports?
Although the Digital Battery Passport and due diligence obligations are separate regulatory requirements, they are becoming increasingly connected.
A Battery Passport is designed to improve transparency across the battery lifecycle. At the same time, due diligence requires organisations to understand and manage risks within their supply chains.
These objectives complement one another.
The information collected through supply chain due diligence can support several categories of Battery Passport data, including battery identification, material composition, responsible sourcing information and sustainability-related documentation. Likewise, well-structured Battery Passport data can make it easier for organisations to demonstrate traceability and maintain consistent records across suppliers and manufacturing processes.
For many organisations, preparing a Digital Battery Passport provides an opportunity to strengthen wider due diligence processes rather than treating them as separate compliance projects.
Supply Chain Data Will Become Increasingly Important
One of the strongest messages from Regulation (EU) 2025/1561 is the growing importance of supply chain visibility.
Economic operators are expected to establish management systems capable of identifying suppliers, tracing relevant information, assessing risks and maintaining documentation that supports their due diligence obligations.
This highlights why data quality should be treated as a strategic asset rather than an administrative exercise.
Battery manufacturers are increasingly expected to know not only where materials originate, but also how relevant risks have been identified, assessed and managed throughout the supply chain. Maintaining structured, verifiable and up-to-date information becomes significantly easier when organisations establish consistent digital data management processes from the outset.
Documentation And Record Keeping Matter More Than Ever
The delegated regulation also places considerable emphasis on documentation.
Organisations should maintain evidence demonstrating that due diligence policies have been implemented effectively, risks have been assessed appropriately, and corrective actions have been taken where necessary.
For Battery Passport implementation teams, this reinforces the importance of robust information governance.
Data should remain accurate, traceable and accessible throughout the battery lifecycle. Reliable storage, version control and secure record management all contribute to maintaining trustworthy Battery Passport information while supporting wider regulatory obligations.
If you are interested in this topic, BASE's article "Battery Passport Data Storage And Archiving Requirements: What Every Organisation Should Know" explores practical considerations for data retention, backups and long-term information management.
Due Diligence Is An Ongoing Process
One important clarification provided by Regulation (EU) 2025/1561 is that due diligence should not be viewed as a one-time assessment.
Supply chains evolve. Suppliers change. Risks emerge and develop over time.
For this reason, organisations should establish processes for continuous monitoring, periodic review and ongoing improvement of their due diligence systems.
Digital Battery Passports can support this approach by providing a structured environment for managing lifecycle information and maintaining up-to-date records that remain relevant as batteries move through manufacturing, use, repair, repurposing and recycling.
How BASE Supports Trusted Battery Data
The BASE project is helping develop and validate interoperable Digital Battery Passport solutions that support secure data exchange, lifecycle traceability and greater transparency across the battery value chain.
As regulatory requirements continue to evolve, projects such as BASE demonstrate how Digital Battery Passports can contribute to trusted information management while supporting broader sustainability and circular economy objectives. Reliable digital data structures can also provide a strong foundation for organisations seeking to align Battery Passport implementation with wider due diligence responsibilities.
Looking Ahead
Regulation (EU) 2025/1561 does not fundamentally change the purpose of battery due diligence. Instead, it provides greater detail on how organisations should implement the obligations already introduced by the Batteries Regulation.
For Battery Passport teams, the message is clear. Strong supply chain governance, reliable documentation and high-quality data management are becoming increasingly interconnected.
Organisations that invest in structured digital information today will be better positioned to meet both Battery Passport requirements and the broader expectations surrounding responsible sourcing and due diligence as the EU's battery regulatory framework continues to mature.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
- EUR-Lex - Commission Delegated Regulation (EU) 2025/1561: https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng
- EUR-Lex - Regulation (EU) 2023/1542 Concerning Batteries and Waste Batteries:
https://eur-lex.europa.eu/eli/reg/2023/1542/oj - European Commission - Digital Product Passport for Batteries:
https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en - OECD - Due Diligence Guidance for Responsible Business Conduct:https://www.oecd.org/en/publications/2018/02/oecd-due-diligence-guidance-for-responsible-business-conduct_c669bd57.html
- OECD - Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: https://www.oecd.org/en/publications/2016/04/oecd-due-diligence-guidance-for-responsible-supply-chains-of-minerals-from-conflict-affected-and-high-risk-areas_g1g65996.html
- BASE Project - DIN DKE SPEC 99100 Explained: The Technical Standard Behind Battery Passport Data Fields: https://base-batterypassport.com/blog/technology-7/din-dke-spec-99100-explained-the-technical-standard-behind-battery-passport-data-fields-123
- BASE Project - JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice: https://base-batterypassport.com/blog/regulations-4/jtc-24-standards-explained-for-battery-passport-teams-what-they-mean-in-practice-115