Changes to battery due diligence?

The core element of the Omnibus IV proposal is a postponement of the date of application of the due diligence obligations under the EU Batteries Regulation by 2 years. This time should give those affected the opportunity to prepare themselves better (e.g. with guidelines) or time to set up notified bodies and recognised systems.

As reported by the European Commission, on 21 May 2025 it also addressed the due diligence obligations under the EU Batteries Regulation (BattR) as part of its Omnibus IV package. Further information on the Omnibus IV package can be found in the following two links:

  1. Commission proposes simplification measures to save EU businesses a further €400 million per year
  2. Omnibus IV Simplification Package

As part of this omnibus package, the "Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2023/1542 as regards the obligations of economic operators concerning battery due diligence policies" has been published. Please find the draft in the following link: COM(2025) 258 final

Here you will find a summary of the key elements of the proposal:

  • Postponement of the date of application of the due diligence obligations under the EU Batteries Regulation by 2 years (new date of application 18/08/2027).
  • Guidelines are to be published by 26 July 2026.
  • If possible, guidelines should be developed "hand in hand" with the CSDDD guidelines.
  • No substantive changes planned.

Background:

  • Time for economic players to prepare themselves better (e.g. with guidelines).
  • Time to set up notified bodies and recognised systems.

Please note, however, that this is a proposal. The development and the specific content after the decision has been made must be monitored further. Our legal monitoring service will help you to keep an eye on this development.

Questions about battery due diligence obligations or the EU Batteries Regulation? The trade-e-bility consulting team will be happy to help you via +49/40/750687-300 or send us an e-mail.

BattR training now available

The EU Batteries Regulation (EU) 2023/1542 is – alongside the EU Packaging Regulation – one of the most important to-do topics for sellers, producers and distributors of batteries and rechargeable batteries in the coming months. Due to the great interest in the EU Batteries Regulation, we recommend that you request your personalised EU Batteries Regulation online training course in good time and without obligation.

Request BattR training now!

Questions? Contact us now without obligation

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