SCRM Supplier Compliance & Risk Management

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Regulation (EU) 2023/1542 · staggered application

Every battery contains a chain that has to be evidenced.

The Battery Regulation requires economic operators to run a due diligence system for cobalt, natural graphite, lithium and nickel – back to the origin of the raw materials.

The regulation replaces the old battery directive and governs the whole life cycle: sustainability, labelling, recycled content, take-back and due diligence. The supply chain part requires an OECD-aligned system that identifies, mitigates and documents risks in sourcing those raw materials.

It reaches beyond battery manufacturers. Placing a device with a built-in battery on the market attaches you to the same chain – and you need data from your suppliers. The application dates of individual duties are staggered and have been adjusted repeatedly.

Who is affected

  • Manufacturers and importers of batteries of all categories.
  • Companies placing devices with built-in batteries on the market.
  • Swiss suppliers to those companies – through their customer’s data request.
  • Trading tiers that must answer on the origin of materials.

What is required

System
A documented due diligence system with ownership and management structure.
Raw materials
Trace cobalt, natural graphite, lithium and nickel along the chain.
Risks
Identify, assess and mitigate social and environmental risks.
Verification
Third-party verification of the system.
Disclosure
Report on the due diligence performed.

How SCRM covers it

Material per supplier

Which supplier delivers which material from which origin.

Collect declarations

Send requests digitally and surface what is still outstanding.

Versioned risk assessment

The trail shows what was known when – the core of any due diligence.

Records for verification

Pre-sorted rather than assembled shortly before the date.

Frequently asked

We build devices, not batteries. Are we affected?

Placing a device with a built-in battery on the market makes you part of the chain, and origin data will be requested. The manufacturer’s duty travels onward by contract.

What applies from when?

Duties enter into force in stages and have been adjusted several times. Check the timetable in force before acting.

Is this like the conflict minerals regulation?

The structure is related – OECD approach, third-party verification, reporting. The materials and thresholds differ.

As of July 2026. Application dates have shifted repeatedly; verify before relying on this. Not legal advice.

Contact

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