Chapter VIII is a management system, a verification route, and a public reporting duty.
The program has to operate continuously from 18 August 2025 and retain records for 10 years after the last battery covered by the policy is placed on the market.
Structured answer sets in this page tree.
Cited legal and guidance references.
The due diligence chapter is sometimes treated as an ESG appendix. That is a mistake. Articles 48 to 52 create an operational program with top management ownership, chain of custody controls, supplier contract clauses, grievance mechanisms, risk mitigation planning, notified body verification, periodic audits, and annual public reporting.
From 18 August 2025, economic operators placing batteries on the market or putting them into service must fulfil the due diligence obligations in Article 48 paragraphs 2 and 3 and in Articles 49, 50, and 52, and must set up and implement battery due diligence policies. Those policies must be verified by a notified body and periodically audited by that notified body.
The retention rule is long. Documentation demonstrating fulfilment must be kept for 10 years after the last battery manufactured under the relevant policy has been placed on the market.
Article 49 requires a management system, not only a public statement. The operator must adopt and communicate a battery due diligence policy, align it with recognized instruments, assign top management oversight, maintain chain of custody or traceability information, incorporate due diligence clauses into supplier contracts, and operate a grievance and remediation mechanism.
This means procurement, legal, and sustainability teams all have to work from the same control framework.
Article 50 requires actual risk identification, assessment, mitigation, monitoring, and escalation. The operator must identify risks in the supply chain linked to the Annex X risk categories, design and implement a risk response strategy, monitor mitigation efforts, report findings back to top management, and consider suspension or discontinuation where mitigation fails.
Where trade continues during mitigation, the operator must consult suppliers and relevant stakeholders before establishing the measurable risk mitigation strategy.
The notified body verification is not ceremonial. Article 51 says the verification should cover all activities, processes, and systems used to fulfil the due diligence obligations, and it should identify areas of potential improvement. The notified body issues a verification report and, where the policy conforms, an approval decision.
Article 52 then turns the program outward. The operator must provide verification materials to authorities on request, make relevant information available to immediate downstream purchasers, and annually publish a public report on the due diligence policy and significant adverse impacts and how they were addressed.
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