Sustainability Due Diligence Requirements In The EU Batteries Regulation

European Regulation 2023/1542, concerning batteries and waste batteries (the "EUBR"), is a dark horse. While it includes a number of restrictions associated with hazardous materials embedded in batteries, and Extended-Producer-Responsibilty provisions (as expected with respect to Equipments such as batteries), it also includes traceability and sustainability due diligence requirements.

The Corporate Sustainability Due Diligence Directive, whose implementation was recently postponed by the April 14, 2025, Stop the Clock Directive, is not the only one to require "duty of care". Other sectorial regulations include such requirements. In particular:

• The EU Conflict Mineral regulation, which primarily targets EU importers or smelters and requires traceability for tin, tantalum, tungsten and gold;