This questionnaire structure helps collect supplier evidence for battery due diligence under Chapter VII of Regulation (EU) 2023/1542.
It focuses on Annex X raw materials, supply-chain traceability, risk management, third-party verification, downstream disclosure, and records that can withstand review.
Structured answer sets in this page tree.
Cited legal and guidance references.
A Batteries Regulation supplier questionnaire should collect the specific supplier facts an in-scope economic operator needs for Articles 49, 50, 51 and 52: whether cobalt, natural graphite, lithium, nickel, or covered compounds are present; who supplied them; where they originated; how they moved through the supply chain; what risks were identified; what mitigation was agreed; and which verification or disclosure record supports the answer. A completed questionnaire is supplier input, not proof of compliance or notified-body verification. Regulation (EU) 2025/1561 postponed the binding Chapter VII start to 18 August 2027, so an earlier questionnaire is readiness work rather than evidence that the duties already apply.
Start the questionnaire with a scope-and-date screen. Article 47 uses the operator's net turnover in the financial year preceding the last financial year. Chapter VII does not apply where that turnover was below EUR 40 million and the operator is not part of a parent-subsidiary group whose consolidated turnover exceeds EUR 40 million. The same chapter excludes the specified placing-on-market or putting-into-service act for batteries already placed on the market or put into service before preparation for re-use, preparation for repurposing, repurposing, or remanufacturing. For operators not excluded, the amended obligations begin on 18 August 2027.
If the buyer is in scope, route the supplier questionnaire by battery model, battery category, raw material, and supplier tier. Do not ask a supplier to certify the whole Batteries Regulation; ask for evidence tied to the raw materials and risk categories in Annex X.
Article 49 turns the questionnaire into a traceability instrument. Supplier answers should give the buyer enough information to maintain a system of controls and transparency, including chain of custody or traceability that identifies upstream actors.
The most useful format is a line-item table per raw material and battery model. Each row should separate supplier assertions from attached evidence so procurement can follow up without rewriting the answer.
Use the questionnaire to connect each supplier answer to Annex X raw materials, traceability evidence, risk mitigation, verification, disclosure, and retention records.
The questionnaire should ask suppliers to identify and explain risks, not merely confirm that a policy exists. Article 50 requires identification and assessment of adverse-impact risks in the supply chain and a strategy to prevent, mitigate, or otherwise address them.
Use Annex X as the risk taxonomy. Require suppliers to mark each risk as not applicable, identified, mitigated, under mitigation, or escalated, and require evidence for the status selected.
A supplier questionnaire is incomplete if it stops at supplier declarations. It should collect the evidence that the economic operator can show to authorities, immediate downstream purchasers, notified bodies, and public-report reviewers.
Separate confidential supplier data from information that may feed annual public reporting. Article 52 requires information to downstream purchasers with regard for business confidentiality and requires a public report on the policy, significant adverse impacts, how they were addressed, and a summary of third-party verifications.
The Regulation does not prescribe an official supplier questionnaire or mandatory wording. Use this working structure to make missing evidence visible, and keep it stable across suppliers so buyer teams can compare responses for the same raw material and battery model.
Every question should produce one of four outputs: a scope answer, a traceability field, a risk-management status, or an evidence attachment. Questions that do not feed one of those outputs should be removed or moved to a separate supplier sustainability assessment.
"sourcing, processing and trading of raw materials"
"rules covering the entire life cycle of batteries"
"make available to its immediate downstream purchasers all relevant information"
"18 August 2027"
"Free search"