The EU Battery Regulation (EU) 2023/1542 introduces due diligence obligations for certain battery raw-material supply chains from 18 August 2027. German retail associations HDE, BVT and BHB argue that many retailers cannot implement the current requirements with sufficient legal certainty. They seek a revision and, if changes cannot be made in time, a further delay of at least twelve months.
EU Battery Regulation: What does due diligence cover?
The requirements address human rights and environmental risks associated with battery raw materials. Businesses within scope must establish a management system, identify risks and document their response. External verification and public reporting are also required. Chapter VII and Annex X of the EU Battery Regulation set out the framework.
These duties do not automatically apply to every retailer. A key question is whether an operator first places batteries on the EU market or puts them into service, including batteries incorporated in appliances. Article 47 also exempts operators with net turnover below EUR 40 million in the financial year preceding the last financial year, provided the relevant consolidated group threshold is not exceeded. Business role, turnover and group structure therefore need to be assessed together.
Why German retailers want changes
The associations say retailers are being asked to take responsibility for stages they cannot control, such as mining and battery production. Retailers often lack direct access to reliable upstream information. Independently checking suppliers’ statements can also be difficult.
In their joint position, HDE, BVT and BHB criticise missing implementation guidance, notified bodies and clarity on audit procedures. This is the associations’ assessment. They want responsibility to reflect actual influence over sourcing, manufacturing and supply-chain management.
They also call for the EU Battery Regulation to be aligned with the Corporate Sustainability Due Diligence Directive, CSDDD. Their aim is to avoid duplicate checks and conflicting requirements. They urge Germany’s government to pursue simplification in Brussels and demand effective enforcement against third-country sellers using international platforms.
A requested delay does not change the 18 August 2027 deadline
The EU has already moved the original application date back by two years. The Council’s account of the adopted amendment confirms 18 August 2027. The additional twelve months now sought by retailers are an industry demand, rather than an adopted extension.
Companies should therefore keep preparing. Imports of smartphones, laptops, power tools and household appliances containing batteries may be relevant. However, selling such products alone does not establish a Chapter VII obligation: the specific scope must first be checked.
What manufacturers and retailers should do now
First, establish your role and assess the turnover and group conditions. Next, map relevant batteries and suppliers, organise evidence and assign responsibilities. Follow further EU decisions while continuing preparation. Registration, labelling and take-back are separate obligations with their own scope and deadlines. A possible change to raw-material due diligence does not automatically suspend them.
ECOPV-EU supports manufacturers and retailers with battery compliance in Germany and the EU. This article provides general information and does not constitute legal advice.
Sources: HDE/BVT/BHB position published by Handelsverband OWL on 27 October 2026; EU Battery Regulation, Articles 47–52; Council of the EU. Checked on 28 October 2026.
AI-generated concept illustration of battery supply chains; it does not depict an approved postponement.
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