Battery Due Diligence probably Postponed to 2027 – European Commission Reschedules Key Deadlines

On 21 May 2025, the European Commission issued a proposal to amend Regulation (EU) 2023/1542, introducing a two-year postponement of key compliance dates for battery due diligence obligations.

Two More Years to Prepare – New Date: 18 August 2027

Originally set to apply from 18 August 2025, the obligations – concerning responsible sourcing of raw materials such as cobalt, lithium, nickel, and graphite – are possibly now proposed to take effect from 18 August 2027. This extension aims to address serious implementation bottlenecks, including the lack of designated notified bodies across Member States and the underdevelopment of due diligence schemes necessary for third-party verification. 

Battery Due Diligence Pushed to 2027? European Commission Proposes Timeline Change

In parallel, the Commission proposes to delay the deadline for publishing implementation guidelines under Article 48(5) of the Regulation from 18 February 2025 to 26 July 2026. This shift is intended to harmonise the timing with the guidance required under Directive (EU) 2024/1760 on corporate sustainability due diligence, thereby enhancing legal consistency for companies subject to both legal frameworks.

The proposed amendments are strictly temporal and do not alter the substantive obligations under Regulation 2023/1542. The Commission emphasises that additional preparation time will allow economic operators to restructure supply chains, respond to geopolitical uncertainties, and integrate new compliance mechanisms.

Importantly, the deferral is framed as a response to the current regulatory gap: only half of the Member States have so far appointed notifying authorities, and no due diligence scheme under Article 53 has been recognised to date.

What Does This Mean for the Industry?

For investors active in the battery value chain, this legislative adjustment provides clarity and breathing room. The amendment should enter into force the day after publication in the Official Journal and apply from 18 August 2025, formalising the deferred timelines.

Find out what you need to do before 2027! Contact our team and get ready in advance.