EU Batteries Regulation Supplier Due Diligence Questionnaire

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.

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 battery due diligence 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.

For each battery model and covered raw material, ask: "What is the material trade name and type? Who supplied it, and at which address? What is its country of origin? Which transactions connect extraction to your supply? What percentage or weight is present in this battery? Which verification report supports the answer?" Provide an attachment reference and let the respondent mark information as unknown, with a contact and follow-up date. These are working questions, not prescribed legal wording.