Use this questionnaire structure to 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 due diligence questionnaire should not ask broad ESG questions in isolation. It 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.
Start the questionnaire with a scope screen. Chapter VII does not apply to economic operators below the EUR 40 million net-turnover threshold unless they are part of a group that exceeds that threshold on a consolidated basis. The same chapter also excludes batteries that were already placed on the market or put into service before preparation for re-use, preparation for repurposing, repurposing or remanufacturing.
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 battery due diligence policy, significant adverse impacts, how they were addressed, and a summary of third-party verifications.
The questionnaire should be concise enough that suppliers complete it, but detailed enough that missing evidence is visible. Keep the structure 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"
"sourcing, manufacturing, use and recycling are addressed"
"make available to its immediate downstream purchasers all relevant information"
"free-search"