EU Batteries RegulationSupplier controls

EU Batteries Regulation (Regulation (EU) 2023/1542) Supplier due diligence questionnaire

A supplier questionnaire is only useful if it collects the evidence your notified body and downstream customers will actually need.

This version is organized around Articles 49 to 52, not around generic ESG prompts.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

Articles 48 to 52 make supplier evidence the critical path for battery due diligence. A weak questionnaire creates false comfort because it collects policy language but not the traceability, risk, audit, and remediation material that the economic operator must maintain for 10 years after the last battery under the policy is placed on the market.

Section 1

Section 1: supplier identity and covered materials

Start by fixing the scope. Ask the supplier which raw materials listed in Annex X are relevant to the batteries or active materials supplied, which facilities are involved, and which exact products or model families are covered by the response.

If the supplier cannot identify the covered facilities or materials, the later answers will not be reliable enough for Article 49 traceability.

  • Legal entity name, site list, and contact owner for due diligence.
  • Covered battery models, cell components, or raw materials.
  • Country of origin and processing route for each covered raw material.
  • Immediate supplier chain and upstream actor identification where available.
Section 2

Section 2: management system and policy controls

Ask for the documented due diligence policy, the standards used to shape it, the top management owner, the grievance mechanism, and the contract clauses used with upstream suppliers. Article 49 is explicit that the management system must be tied to top management oversight, contract controls, traceability, and grievance handling.

This is also where you test whether the supplier policy is battery specific or merely a generic supplier code.

  • Battery due diligence policy and date of last review.
  • Top management owner and governance route for escalations.
  • Supplier contract clauses covering traceability, mitigation, and cooperation.
  • Grievance, early warning, and remediation mechanism description.
Recommended next step

Keep EU Batteries Regulation (Regulation (EU) 2023/1542) Supplier due diligence questionnaire in one governed evidence system

SSOT can take EU Batteries Regulation (Regulation (EU) 2023/1542) Supplier due diligence questionnaire from reusing this material inside a governed evidence system to a reusable workflow inside Sorena. Teams working on EU Batteries Regulation (Regulation (EU) 2023/1542) can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 3

Section 3: traceability and chain of custody evidence

Article 49 requires a chain of custody or traceability system identifying upstream actors in the supply chain. Ask for actual evidence fields, not only process descriptions. The minimum useful response covers the material type, supplier identity, country of origin, transaction chain, quantities, and any third party verification reports already available.

Where material comes from conflict affected or high risk areas and third party reports are not available, ask for the additional OECD style information the Regulation points to.

  • Material name, trade name, and type.
  • Supplier name and address for the supplied material.
  • Country of origin and transaction path from extraction to immediate supplier.
  • Quantities present in the supplied battery or component.
  • Existing third party verification reports or equivalent evidence.
Section 4

Section 4: risk assessment, mitigation, and verification

Article 50 requires risk identification, risk assessment, measurable mitigation, monitoring, and reporting back to top management. Ask for the current risk register, active mitigation plan, supplier escalation criteria, and how failed mitigation triggers suspension or disengagement. Also ask for any notified body verification or supplier level verification reports the operator may rely on.

The goal is to see whether the supplier can support the operator own risk management plan, not merely state that it complies with OECD guidance.

  • Current risk register for Annex X social and environmental risk categories.
  • Measurable mitigation plan with owners and dates.
  • Evidence of stakeholder consultation where mitigation is ongoing.
  • Notified body or other verification reports and latest audit outcomes.
  • Corrective actions open, overdue, and closed in the last reporting cycle.
Section 5

Section 5: downstream disclosure support

Article 52 requires annual public reporting and downstream information sharing. Suppliers should therefore be asked which data can be passed to immediate downstream purchasers, which information is confidential, and how changes will be communicated. A supplier that cannot support downstream disclosure will create recurring remediation work.

This section also helps align the questionnaire with the operator public report and customer diligence requests.

  • Information available for downstream purchasers.
  • Confidentiality limits and approved disclosure boundaries.
  • Update cadence for material changes or significant adverse impacts.
  • Named contact for urgent authority or customer follow up questions.
Primary sources

References and citations

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