---
title: "Battery Due Diligence Program"
canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/due-diligence-program"
source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/due-diligence-program"
author: "Sorena AI"
description: "Build a battery due diligence program for Regulation (EU) 2023/1542 with an Article 48 policy, Article 49 management system and traceability."
published_at: "2026-02-21"
updated_at: "2026-02-21"
keywords:
  - "battery due diligence program"
  - "Article 48 Article 49 Article 50 Article 51 Article 52 batteries"
  - "EU Batteries Regulation due diligence"
  - "notified body battery due diligence"
  - "battery raw materials due diligence"
  - "EU Batteries Regulation"
  - "Due diligence"
  - "Article 48"
  - "Article 49"
  - "Article 51"
---
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# Battery Due Diligence Program

Build a battery due diligence program for Regulation (EU) 2023/1542 with an Article 48 policy, Article 49 management system and traceability.

*EU Batteries Regulation* *Chapter VIII*

## EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program

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.

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.

## Article 48 foundation and timing

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.

- Go live date: 18 August 2025.
- Verification route: notified body third party verification and periodic audit.
- Retention rule: 10 years after the last covered battery is placed on the market.
- Possible collaboration through due diligence schemes does not remove the operator own responsibility.

## Article 49 management system requirements

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.

- Top management owner and governance route.
- Chain of custody or traceability system identifying upstream actors.
- Supplier contract clauses covering risk management and cooperation.
- Grievance, early warning, and remediation mechanism.
- Record retention embedded into the management system.

## Article 50 risk management requirements

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.

- Risk register tied to the Annex X risk categories.
- Measurable risk mitigation plan with owners and dates.
- Escalation to top management and supplier action route.
- Follow up assessments after changes in circumstances or failed mitigation.

## Article 51 verification and Article 52 disclosure

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.

- Prepare the verification evidence room before the first notified body review.
- Track approval decisions, audit reports, and open improvements.
- Publish the annual public report in a way that clearly identifies the batteries concerned.
- Prepare a downstream information sharing package with confidentiality boundaries.

*Recommended next step*

*Placement: near the end of the main content before related guides*

## Operationalize EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program across ESG workflows

ESG Compliance can take EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program from operationalizing this sustainability obligation across workflows and reporting 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.

- [Open ESG Compliance for EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program](/solutions/esg-compliance.md): Start from EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program and manage cross team sustainability work, reporting, and evidence from one workflow.
- [Talk through EU Batteries Regulation (Regulation (EU) 2023/1542)](/contact.md): Review your current process, evidence gaps, and next steps for EU Batteries Regulation (Regulation (EU) 2023/1542) Due diligence program.

## Primary sources

- [Regulation (EU) 2023/1542 - Official Journal](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal text for scope, categories, dates, economic operator duties, waste obligations, and battery passport rules.
- [European Commission - Batteries overview](https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en?ref=sorena.io) - Commission implementation page for Batteries Regulation updates and related acts.
- [SMCS or NANDO notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - Official search entry for notified bodies relevant to Regulation (EU) 2023/1542.

## Related Topic Guides

- [Battery Carbon Footprint Declarations | Article 7 Implementation Guide](/artifacts/eu/batteries-regulation/carbon-footprint-declarations.md): Implement the carbon footprint declaration requirements in Article 7 of Regulation (EU) 2023/1542 with plant specific battery model declarations.
- [Battery Due Diligence Supplier Questionnaire | EU Batteries Regulation](/artifacts/eu/batteries-regulation/battery-due-diligence-supplier-questionnaire.md): Use a practical supplier questionnaire for the battery due diligence obligations in Articles 48 to 52 of Regulation (EU) 2023/1542.
- [Battery Labeling and Consumer Information | Article 13 and Article 74 Guide](/artifacts/eu/batteries-regulation/labeling-and-consumer-information.md): Implement battery labeling, QR code, and consumer information duties under Regulation (EU) 2023/1542, including the separate collection symbol.
- [Battery Passport Data Model Template | Annex XIII Ready Structure](/artifacts/eu/batteries-regulation/battery-passport-data-model-template.md): Design a battery passport data model for Regulation (EU) 2023/1542 using the Annex XIII access tiers for public model data, legitimate interest data.
- [Battery Passport Implementation | Article 77 and Article 78 Guide](/artifacts/eu/batteries-regulation/battery-passport-implementation.md): Implement the EU battery passport for LMT batteries, industrial batteries above 2 kWh, and EV batteries with a compliant QR resolver, Annex XIII data model.
- [Battery Recycled Content and Recovery Targets | Article 8 and Annex XII Guide](/artifacts/eu/batteries-regulation/recycled-content-and-recovery-targets.md): Understand the recycled content roadmap in Article 8 and the recycling efficiency and material recovery targets in Annex XII.
- [EU Batteries Regulation Applicability Test | Category, Scope, and Obligation Routing](/artifacts/eu/batteries-regulation/applicability-test.md): Run a grounded applicability test for Regulation (EU) 2023/1542 by checking whether the battery is portable, LMT, SLI, industrial, or EV.
- [EU Batteries Regulation Battery Categories and Scope | Portable, LMT, SLI, Industrial, EV](/artifacts/eu/batteries-regulation/battery-categories-and-scope.md): Use the legal category definitions in Regulation (EU) 2023/1542 to classify batteries as portable, LMT, SLI, industrial, or EV.
- [EU Batteries Regulation Checklist | Practical Compliance Checklist by Battery Category](/artifacts/eu/batteries-regulation/checklist.md): Use a detailed checklist for Regulation (EU) 2023/1542 covering battery classification, labeling, QR, battery passport, carbon footprint declarations.
- [EU Batteries Regulation Compliance Program | Build an Operational Batteries Program](/artifacts/eu/batteries-regulation/compliance.md): Build a practical compliance program for Regulation (EU) 2023/1542 covering battery classification, technical documentation, carbon footprint declarations.
- [EU Batteries Regulation Deadlines and Compliance Calendar | Exact Dates and Workplan](/artifacts/eu/batteries-regulation/deadlines-and-compliance-calendar.md): Track the exact dates in Regulation (EU) 2023/1542, including application from 18 February 2024, Article 14 and Chapter VI timing from 18 August 2024.
- [EU Batteries Regulation FAQ | Dates, Categories, Passport, Due Diligence, and Waste Duties](/artifacts/eu/batteries-regulation/faq.md): Get grounded answers to common questions on Regulation (EU) 2023/1542, including the main application date, when battery passport starts.
- [EU Batteries Regulation Penalties and Enforcement | Article 93 Guide](/artifacts/eu/batteries-regulation/penalties-and-fines.md): Understand the penalty and enforcement structure in Regulation (EU) 2023/1542.
- [EU Batteries Regulation Requirements | Article by Article Requirement Map](/artifacts/eu/batteries-regulation/requirements.md): Get a practical map of the main requirements in Regulation (EU) 2023/1542, including category rules, carbon footprint, recycled content, removability.
- [EU Batteries Regulation vs ESPR | Battery Passport vs Digital Product Passport](/artifacts/eu/batteries-regulation/batteries-regulation-vs-espr.md): Compare the battery passport in Regulation (EU) 2023/1542 with the broader ESPR Digital Product Passport model.


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