Battery Minerals Due Diligence

Battery minerals due diligence refers to the supply chain transparency and risk management obligations applicable to minerals used in battery manufacturing, including cobalt, lithium, graphite (natural), nickel, copper, and manganese. While not classified as 3TG conflict minerals under Dodd-Frank, these minerals are subject to growing due diligence requirements under the EU Battery Regulation (EU) 2023/1542, emerging ESG frameworks, and customer-driven reporting via the EMRT and AMRT templates.

EU Battery Regulation (EU) 2023/1542; RMI EMRT v.2.11 (April 2026); EU Corporate Sustainability Due Diligence Directive (CS3D); OECD Due Diligence Guidance.

Companies in the EV, electronics, and energy storage sectors increasingly face battery minerals due diligence requirements from customers and regulators. The EU Battery Regulation mandates supply chain due diligence for cobalt, natural graphite, lithium, and nickel for batteries placed on the EU market above certain thresholds. The EMRT is the primary standardized tool for collecting battery minerals supply chain data. Companies should integrate EMRT collection alongside CMRT for comprehensive mineral coverage.

An EV manufacturer subject to the EU Battery Regulation must collect EMRT declarations from suppliers covering cobalt and lithium smelters/processors. The manufacturer must identify processor-level data and assess whether these minerals originate from conflict-affected or high-risk areas per OECD Due Diligence Guidance.