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LONDON, Jan 17 (Reuters) - Automotive Cells Co (ACC) has partnered with UK startup Circulor to check the provenance and embedded carbon emissions of raw materials the France-based battery maker uses for electric vehicle (EV) battery cells, the two companies said on Wednesday.

ACC is a joint venture between Stellantis (STLAM.MI), opens new tab, TotalEnergies (TTEF.PA), opens new tab and Mercedes-Benz Group (MBGn.DE), opens new tab.

Launched in 2020, ACC has announced EV battery plants in France, Germany and Italy with a 7 billion-euro ($7.6 billion) investment. The French plant should start mass production soon.

Circulor, which uses blockchain technology to map supply chains for companies pursuing greener production, already works with a range of companies including Volvo Cars (VOLCARb.ST), opens new tab, BMW (BMWG.DE), opens new tab and BHP (BHP.AX), opens new tab.

European battery maker ACC partners with Circulor to map supply chain, carbon emissions

News

TUV partnership

LONDON, 26 May 2025 - TÜV Rheinland Greater China (referred to as "TÜV Rheinland"),  the international independent third-party testing, inspection, and certification organization signed a strategic cooperation agreement with Circulor, the leading global supply chain traceability provider on in-depth cooperation in digital services, such as digital product passports, supply chain traceability and management, and global regulatory compliance. 

Together, they will help enterprises handle global sustainability regulatory requirements, while enhancing compliance capabilities and demonstrating international market competitiveness.

With the strong performance of China's “New Three” industries of electric vehicles, lithium batteries, and photovoltaic products, global supply chain management and sustainable product development have become key factors for enterprises to expand into overseas markets. Especially after the official implementation of the EU Battery Regulation (EU) 2023/1542 and the Sustainable Product Eco Design Regulation (EU) 2024/1781, compliance requirements such as material traceability, carbon footprint transparency, and sustainable design are increasingly strengthened, and enterprises face unprecedented compliance and data management challenges.

In this context, TÜV Rheinland and Circulor have established a strategic partnership to jointly provide integrated solutions covering supply chain traceability, product eco-design verification, and passport data verification for global customers. Both parties will jointly develop innovative services for future needs, including digital product passport services based on the EU Batteries Regulation and Ecodesign for Sustainable Products Regulations, supply chain management platform solutions for international regulations or customized enterprise needs, and collaborate to develop new markets through the establishment of technical exchange and cooperation mechanisms.

"Our strategic partnership builds on our existing relationship with TÜV Rheinland. Together with their global influence and reach, we jointly support enterprises with the practical implementation of digital product passports and supply chain traceability - enabling Chinese enterprises to expand and trade internationally in the face of growing regulatory requirements across multiple markets.”

Xia Bo, Senior Vice President of Solar & Commercial Products at TÜV Rheinland Greater China said, "Through this strategic cooperation, we hope to provide full process and full lifecycle digital compliance services for enterprises in the battery value chain, especially in supply chain management, to help Chinese manufacturers and exporters accelerate their internationalization efforts while enhancing their competitiveness in the international market.”

In the field of digital battery passports, TÜV Rheinland can provide technical support and services such as regulatory interpretation, digital battery passport generation, and passport content technical support, committed to providing sustainable and implementable digital compliance solutions for enterprises. 

In the future, TÜV Rheinland and Circulor will leverage their respective professional capabilities and technological advantages to jointly explore global market opportunities and lead the high-quality development of the battery industry.

TUV partnership 2

Representatives from Circulor, Asia Pacific Vice President Yue Jin Tay, Client Partner Aloysius Lim, TÜV Rheinland Greater China Senior Vice President of Solar Energy and Commercial Product Services Xia Bo, Sustainable Business Manager Lin Li, and Strategic Business Development Manager Ding Shufen attended the signing ceremony.

Circulor and TÜV Rheinland reach strategic cooperation to jointly promote digital sustainable compliance services

Press Releases

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— Circulor, the global leader in supply chain traceability and sustainability solutions, is pleased to announce the appointment of Giles Palmer as Chief Executive Officer.

Giles Palmer is renowned for founding Brandwatch, a digital consumer intelligence company, in 2006. Under his leadership, Brandwatch grew into a global enterprise, culminating in its acquisition by Cision in 2021 for $450 million. Following the acquisition, Giles served as Chief Growth Officer at Cision, where he was instrumental in driving strategic initiatives. Most recently, he was the CEO at Cint Group AB, a leader in digital insights and research technology.

At Circulor, Giles will leverage his extensive experience in scaling technology companies to accelerate the company’s mission of making global supply chains more transparent and sustainable. His appointment marks a significant milestone, especially as Circulor expands its global footprint and technological capabilities.

“I am thrilled to join Circulor at this pivotal time,” said Giles Palmer. “The company’s commitment to responsible sourcing aligns with my personal values, and I look forward to leading the team to drive impactful change across industries.”

Doug Johnson-Poensgen, Circulor’s Founder and long-serving CEO, will transition to the role of President. Under Doug’s leadership, Circulor grew from a startup to a global leader in supply chain traceability and battery passporting. 

Circulor gives organizations full visibility of their supply chains. The London-headquartered company offers the most mature, proven, and complete technology software solution to track materials with high environmental and human rights impacts as they change state within manufacturing and recycling supply chains. With Circulor, businesses can follow the physical flow of critical materials from extraction to final production, as well as associated ESG characteristics and embedded carbon across Scope 1, 2, and 3 emissions. The tech company was founded in 2017 and has offices in the UK, Ireland, the U.S., Germany, Singapore, and Australia. The company has been named a 

Circulor appoints Giles Palmer as Chief Executive Officer to lead the company’s next phase of growth 

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 a leading manufacturer of advanced battery systems, today announced a strategic agreement with 

, the leading supply chain traceability provider, and 

. (NYSE: ROK), the world’s largest company dedicated to industrial automation and digital transformation, to deliver next-generation battery energy storage solutions. This collaboration solidifies Acculon’s commitment to responsible sourcing and sustainability with Circulor’s pioneering traceability and digital battery passport solutions and Rockwell’s state-of-the-art manufacturing expertise to accelerate compliance with existing and emerging regulatory standards.

As the demand for next-generation energy storage grows in pursuit of firm, diverse, and clean power, transparency and responsible stewardship become more and more essential. The EU Battery Regulation’s due diligence and digital battery passport requirements, by February 2027, highlight the importance of supply chain traceability and require a shift for companies to prioritize and prove responsible sourcing of critical minerals. This level of product transparency is also required to garner market incentives and meet increasing market import and trade restrictions.

In response, this strategic agreement enables a verifiable data trail for the origin of key materials such as sodium, lithium, copper, nickel, and graphite, as well as the embedded carbon emissions, from source to final battery manufacturing at Acculon’s Ohio facility. Together, they will also implement battery passports for a range of commercial and industrial applications for their customers, providing unprecedented levels of transparency and enabling them to meet upcoming compliance obligations.

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“Acculon Energy is thrilled to partner with Circulor and Rockwell as we advance our commitment to responsible energy storage innovation. Europe is an important export market for Acculon, and working with the best-in-class for traceability is an important step in our entry. Beyond Europe, we aim to give our global customers visibility into the resiliency of the sodium and lithium supply base we’ve put together.”

By incorporating traceability from cell selection through production, the collaboration proves Acculon’s commitment to responsible development and manufacturing, scaling the partnership as Acculon scales output. 

"As the demand for battery energy storage accelerates, so too does the need for accountability in how these systems are built,” 

says Douglas Johnson-Poensgen, CEO and founder of Circulor. 

“We're proud to work with Acculon Energy and Rockwell Automation to prove that transparent, traceable, and responsible supply chains are not only possible, but essential to a resilient energy future."

“Rockwell Automation is proud to support innovative manufacturers like Acculon Energy as they embrace digital transformation,” 

said James Glasson, vice president, Rockwell Automation. 

“By connecting intelligent manufacturing systems with trusted traceability data, we’re helping Acculon scale with confidence and compliance in mind.”

Acculon, along with Circulor and Rockwell’s combined strengths, will deliver significant benefits for consumers of energy storage products navigating the rapidly evolving and increasingly complex market expectations for secure, resilient, and responsible supply chains. This partnership sets a new benchmark for supply chain integrity, product transparency, and compliance readiness in battery energy storage.

Acculon Energy designs and manufactures advanced battery modules and packs—specializing in sodium and lithium-ion—for commercial and industrial applications. Based in Columbus, OH, Acculon brings decades of energy storage expertise to deliver safe, scalable, and efficient solutions that go beyond UL safety standards: safety and quality are core pillars in everything we do. By integrating cutting-edge AI and IoT technologies, Acculon is helping lead the transition to next-generation energy storage, powering smarter, safer, and more sustainable systems, from start to scale. For more information, visit us on 

Rockwell Automation, Inc. (NYSE: ROK), is a global leader in industrial automation and digital transformation. We connect the imaginations of people with the potential of technology to expand what is humanly possible, making the world more productive and more sustainable. Headquartered in Milwaukee, Wisconsin, Rockwell Automation employs approximately 27,000 problem solvers dedicated to our customers in more than 100 countries. To learn more about how we are bringing the Connected Enterprise to life across industrial enterprises, visit  

Circulor gives organizations full visibility of their supply chains. The London-headquartered company offers the most mature, proven, and complete technology software solution available to track materials with high environmental and human rights impacts as they change state within manufacturing and recycling supply chains. The tech company was founded in 2017 in the UK, with offices in the US, Germany, Singapore, Ireland, and Australia. The company has also been named a Technology Pioneer and a Global Innovator by the World Economic Forum, Global Cleantech 100, and won DIGITALEUROPE's 2022 Future Unicorn Award.

Acculon Energy partners with Circulor and Rockwell Automation to enhance supply chain transparency in Energy Storage

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Yesterday, the European Commission released simplification measures for a number of policies, including a proposal to give the battery industry more time to comply with the Due Diligence requirements of the EU Batteries Regulation. 

Assuming and anticipating that this proposal is accepted by the European Parliament and the Council, the new deadline to fulfil and verify the due diligence requirements will shift from August 2025 to August 2027, and the Commission will provide final guidance in July 2026. This gives European Member States time to establish third-party notified bodies and economic operators time to ensure their batteries comply. 

It’s important to be clear that the core requirements of the EUBR and its due diligence obligations (Chapter VII) are not changing—the timeline is simply shifting. 

The EU Batteries Regulation, as already enacted into force in August 2023, still requires: 

Companies shouldn’t see these additional two years as something to squander. As the Commission highlights in its proposals, it takes time to analyze and adjust supply chains, and digitalization remains a critical commitment of theirs to uphold high standards of operations and products, while streamlining and accelerating effective reporting for both companies and authorities. 

In the spirit of European and business competitiveness, we must remember that supply chain transparency and resilience is core to mitigating risks and improving economic strength. 

The ability to differentiate suppliers and products based on high standards is a competitive advantage for Europe, especially when pursuing reindustrialization and investment in batteries and critical minerals. The EUBR and OECD Guidelines have already prompted other markets to follow suit, so whether for this policy or a growing number of others, as well as financial and business obligations, the time to start is now. 

If you'd like to learn more about Circulor's Material Traceability and Battery Passport solution please fill in the form below and we will be in touch. 

While timing may change—EUBR requirements have not

Commentary

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Environmental policies frequently require the automotive industry to shift as regulations change.

Traceability is a key area of focus for Government organisations across the world who are conscious of reducing the carbon footprint produced by the automotive industry. One sector of the industry which may be overlooked by some for its environmental impact is the tyre industry. The tyre industry is at a key moment, facing growing regulatory pressures alongside an increasing need for efficiency, traceability, and sustainability to be optimised.

The upcoming EU Deforestation Regulation (EUDR) represents a key shift for the tyre industry, demanding increased levels of supply chain due diligence. However, although the compliance deadline is fast approaching, many tyre manufacturers are far behind when it comes to implementing the necessary traceability frameworks.

Just Auto spoke to Dominique Scheider, EMEA industry strategy and marketing manager for transportation, Rockwell Automation and Douglas Johnson-Poensgen, CEO of Circulor, to learn more about the upcoming EUDR regulation and why some within the industry are lagging behind.

JUST AUTO: Tracing tyres and the EU Deforestation Regulation

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The collaboration focuses on material traceability from source to lithium iron phosphate battery.

– US-based energy storage integrator Powin has partnered with Circulor, a supply chain traceability solutions provider, to introduce battery passports for energy storage systems in grid applications.

Their collaboration focuses on material traceability from source to lithium iron phosphate battery, setting a new standard for responsible sourcing in the battery energy storage system (BESS) market.

The partnership employs Circulor’s traceability technology to monitor the origins and carbon emissions of key materials such as graphite, lithium, aluminium, steel and copper.

Read the full story from Power Technology 

"The BESS market is growing rapidly and it’s clear why — our power systems need the clean, firm power that batteries can deliver. While we build out this portion of our energy portfolio, I’m thrilled that Circulor and Powin are showing that supply chain responsibility and circularity are of utmost importance, and achievable through transparency and traceability.”

POWER TECHNOLOGY: Powin and Circulor link on battery passports for energy storage systems

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Powin, a U.S.-based global energy storage integrator, and Circulor, the leading supply chain traceability solution, are partnering to deliver battery passports for energy storage systems in grid applications. Underpinned by end-to-end material traceability, this collaboration sets a new standard for responsible sourcing in the battery energy storage system (BESS) market. 

– Powin, a U.S.-based global energy storage integrator, and Circulor, the leading supply chain traceability solution, are partnering to deliver battery passports for energy storage systems in grid applications. Underpinned by end-to-end material traceability, this collaboration sets a new standard for responsible sourcing in the battery energy storage system (BESS) market. 

The partnership, which kicked off this month, implements Circulor’s material traceability solution to track graphite, lithium, aluminum, steel and copper from source to Lithium Iron Phosphate (LFP) batteries, as well as the embedded carbon emissions, providing unparalleled visibility, proof of material provenance, and alignment with Europe’s Batteries Regulation and U.S. import and trade restrictions. 

In addition, all Powin’s battery packs for European markets will come with a digital battery passport, accessible through a QR code - well ahead of meeting Europe’s battery passport deadline of February 2027. Powin will provide product transparency to their customers, enabling them to service and maintain energy storage systems with greater precision and efficiency because they have more detailed production information and in-life performance monitoring.

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"The energy transition requires not only advanced technologies but also a firm commitment to responsible sourcing. Partnering with Circulor enables us to deliver traceable, transparent energy storage solutions that align with global trade and sustainability standards. This is a pivotal step in building a more ethical and resilient supply chain for the clean energy future."

This in-depth transparency for battery energy storage sets Powin apart from other integrators and power producers, differentiating their products with verifiable data on the origin and production journey of their batteries and the sustainability impact. The strategic partnership with Circulor reinforces Powin’s mission to be the world’s most trusted energy storage provider by delivering solutions that offer lasting value and demonstrate a deep commitment to social responsibility.

"The BESS market is growing rapidly and it's clear why—our power systems need the clean, firm power that batteries can deliver. While we build out this portion of our energy portfolio, I’m thrilled that Circulor and Powin are showing that supply chain responsibility and circularity is of utmost importance and achievable through transparency and traceability."

Energy storage is revolutionizing and strengthening the power sector, driving the integration of renewable energy and stabilizing power grids. 

 projects that by 2035, global energy storage capacity will reach 228 gigawatts (965 gigawatt-hours)—a tenfold increase from today’s levels. BESS integrators will play an increasingly crucial role in ensuring grid resiliency, energy security and independence.

Powin and Circulor partner to advance Battery Passports for Utility-Scale Energy Storage Systems

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At the recent SAFE Summit, Circulor’s Douglas Johnson-Poensgen, Aimee Boulanger, Executive Director of Initiative for Responsible Mining Assurance (IRMA) and one of our customers Jeff Werner, VP Corporate & Government Affairs of Panasonic North America, discussed the fundamentals of how traceability is building a ‘better’, more trusted battery supply chain and the challenges that remain in scaling best practices.

Circulor and Panasonic, the largest battery maker in the world, shared how traceability accomplishes and proves responsible sourcing, sustainable production, and growing volumes of recycled content, essential to improving resource security in the realm of critical minerals. They do this by using Circulor’s leading supply chain traceability solution to track raw materials from source, both recycled scrap and mined materials, all the way through the supply chain “to prove who touched what, when, and where”. This is not only increasingly important for Panasonic but also for their customers to satisfy ever-evolving regulatory requirements, including tariffs.

Jeff Werner of Panasonic also shared how traceability builds trust within the system through cross sectoral collaboration, helping companies make the right investments, at a challenging and uncertain time.

If you would like to speak with the team, please fill out the form below and we will be in touch.

Building Better Batteries 

Webinars

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Following Kumi and Circulor's latest webinar on Thursday 20th March 2025, where we discussed the latest due diligence regulatory landscape beyond the EU Batteries Regulation, see below some of your FAQs.

Please fill in the form to access

The EU Omnibus has indicated significant potential changes for CSDDD. What impact will this have on the EUBR's due diligence requirements?	

The EUBR is currently not included in the Omnibus and although future simplification packages planned by the Commission may do so, no substantial changes are expected as of now. Despite uncertainties, we strongly advise companies to continue preparation for their due diligence requirements. In particular, one should follow international frameworks such as the OECD Due Diligence Frameworks and UNGPs that underpin all of the current EU due diligence legislation. 

When will the EUBR due diligence guidelines be published?

Although the EUBR is not part of the current Omnibus negotiations and simplification packages, while negotiations are ongoing, there is currently no confirmed timeline for the publication of the EUBR guidance. 

Can we expect the 18 Aug 2025 deadline for due diligence compliance to be pushed out given delays from the European Commission?

The EUBR due diligence requirements apply from August 18, 2025, no changes to the deadline are known. However, it is likely that notified bodies will not be available in time, in which case third party verification would be postponed until they are in place. The remaining due diligence obligations are still due by August with the exception of public reporting, which is expected to be in force only by August 2026.

Notified bodies have to verify due diligence compliance and currently, no notified bodies have been confirmed and communicated, which means that this requirement will be enforced only once available. The European Commission and Member States are still setting up the process for approving notified bodies. 

We strongly suggest companies continue preparing due diligence requirements rather than waiting for the notification of bodies as adequate implementation requires sufficient lead time, and all other requirements will still be in effect by August 2025, and the first public report is expected to be due by August 2026.

Does third-party verification apply only to the due diligence processes or does each annual report also need to be verified by a third-party?

The notified body will be responsible for periodically verifying an economic operator's implementation of all due diligence requirements listed in Articles 49, 50 and 52, including the performance of implementation and reporting.

Can the reporting obligation under the EUBR be included in other annual non-financial reporting by the company?	

The reporting obligations under the EUBR can be combined with other company reporting obligations, e.g., CSRD. It is important to ensure that the full scope of requirements, risks, raw materials and supply chain stages required under the EUBR are covered.

How important is the role of 2nd life batteries? How can supply chain transparency enable this?	

The role of 2nd life batteries is very important in decabonizing, diversifying power markets and securing critical minerals. The supply chain data, coupled with data in the battery passport, will enable faster and more efficient pathways to second life and ultimately recycling.

How deep should the companies go in their supply chains and where are the key risks?

The EU Battery Regulation states that this must be back to source for both primary and secondary materials, so either the mine site or waste source into recycling facilities. This is to ensure risks in the upstream are identified, managed and mitigated. 

The materials in scope of the EUBR due diligence requirements are cobalt, lithium, nickel and natural graphite given they’re the most common and high-risk materials in batteries.

What approach can companies take when upstream suppliers refuse or are unable to provide necessary information?	

From our experience, collaborating with a neutral third-party traceability provider may support economic operators in engaging with their suppliers. Circulor's established network of battery value chain participants creates efficiencies for new customers. In principle, we recommend collaboration with suppliers to foster understanding regarding the purpose and need of supply chain transparency, including data required under the EUBR. In cases of continued non-cooperation without significant improvement, economic operators should consider long-term business strategies, including the potential suspension or termination of business relationships.

How can we design and implement robust confidentiality protocols that enable effective data sharing across the battery supply chain while ensuring that proprietary information and trade secrets are fully protected and competitive positioning is maintained? 	

The definition of business confidentiality and confidential data varies among companies and across different national jurisdictions. Consequently, a one-size-fits-all approach is not feasible. By nature, there is a trade-off between transparency and confidentiality; however, specific mechanisms can mitigate this tension. For example, economic operators do not require comprehensive access to all information from the start, nor do they need access to all documentation required to verify the chain of custody information. 

For instance, neutral third parties can assess, verify, and confirm data validity without disclosing confidential information to economic operators. How much information needs to be disclosed to the economic operator depends on the risk profile of a supplier and its supply chain, as well as the ability to give assurances that risks are managed appropriately. Ultimately, it is the economic operator who has to decide whether the provided information is sufficient since it bears the responsibility under the law, which cannot be shifted.

FAQs - Tackling global regulatory complexity with supply chain due diligence

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Kumi and Circulor hosted a joint webinar, alongside Senior Human Rights Expert, Charline Daelman of Panasonic, to unpack the global due diligence regulatory landscape - beyond the EU Batteries Regulation. 

Please fill in the form to access the webinar

Kumi and Circulor hosted a joint webinar, alongside Senior Human Rights Expert, Charline Daelman of Panasonic, to unpack the global due diligence regulatory landscape - beyond the EU Batteries Regulation. They discussed the potential impacts of the EU Omnibus and trade restrictions that should shape your global supply chain due diligence strategy.

-	How to future-proof your compliance strategy

-	The importance of collaboration across your supply chains

-	How to structure your due diligence efforts in the face of ambiguity

They also discuss how traceability systems can be used to pinpoint due diligence actions that companies need to undertake in order to identify, assess and respond appropriately to social and environmental risks in battery supply chains.

If you have any questions on the insights shared in this webinar, or how Circulor can support your business, please set-up a meeting with our team 

Hello and welcome. Thank you for joining Kumi and Circulor's second webinar on the topic of supply chain due diligence. We'll give a few minutes to allow everybody to join and then we'll get started.

Great, with that, I think we're ready to get started. Again, thank you for joining Kumi and Circulor's second webinar on the topic of supply chain due diligence.

My name is Ellen Carey. I'm the Chief External Affairs Officer at Circulor, the leading technology provider on supply chain transparency and material traceability. The global regulatory landscape in this space is becoming increasingly complex. Daily news on policies and their requirements, such as the EU Omnibus, leave businesses without much needed clarity.

Building on our previous webinar, today we'll expound on the EU Batteries Regulation, and will also broaden the context, the global regulatory landscape that shapes and informs your company's global supply chain due diligence strategy.

Joining me today, I'm pleased to share Charline Daelman, Senior Human Rights Expert at Panasonic. Alex Graf, Manager at Kumi Consulting and lead on Kumi's work with the European Commission on the EU Battery Regulation. James Lewry, Director of Client Services at Kumi Consulting, and Yue Jin Tay, Vice President for Customer Engagement and Strategy at Circulor.

Today, we'll cover how to approach uncertainty and ambiguity in today's global environment. We'll also talk about how to future-proof your compliance strategy, why collaboration across the value chain is critical, how to think beyond regulations, and how to learn from certain circumstances and efforts underway by those in your peer group.

For the first part of our time, I'd like to invite Yue Jin Tay and James Lewry to set the scene for us, globally, as pertaining to current due diligence policies and practices, and also pertaining to the EU battery regulation, what companies need to do, how are different players preparing given their maturity and their place in the value chain. This is what James and Yue Jin will share with us next.

From there, Charmaine and Alex will join the discussion, and we'll talk about the ambiguities in today's global regulatory landscape, how to address them, and how to tactically keep moving forward to reduce risk and continue preparedness.

Our goal is to make this an informative and valuable conversation for all of you, our audience. And in that spirit, we'll pause a couple times throughout to solicit your insights and experiences via some multiple-choice questions.

We welcome your questions via the Q&A chat function. We've reserved time at the end to address them, but if we get to all of them, please know that the Circulor and the Kumi teams will be coming back to you with answers after the webinar concludes.

Today's session is being recorded and a link to the recording will be sent to all registrants after we conclude. That is all for me, all the housekeeping, etc. I'm now pleased to turn it over to James and to Yue Jin.

Great, thanks so much Ellen and it's really good to be with everybody today. 

So, after the past decade we've seen a dramatic shift from voluntary standards like the OECD guidelines and the UN guiding principles to legally binding due diligence requirements. Businesses are more aware than ever of environmental impacts, forced labour and human rights abuses in the supply chains of the things that we all buy and this has prompted robust regulatory responses worldwide.

So in the US, Canada, Australia, and the EU, new supply chain acts and trade restrictions are tackling modern slavery risks head on. For example, the German Supply Chain Due Diligence Act, and of course the proposed EU Corporate Sustainability Directive are setting new benchmarks for corporate accountability, even with the changes under the omnibus that Ellen mentioned earlier. At the same time, regulations like the EU Deforestation Regulation and Extended Producer Responsibility policies are really pushing sustainability further upstream in the supply chain.

And building on all of these developments, the EU Batteries Regulation now introduces some of the most demanding sustainability and due diligence obligations yet. It captures battery manufacturers and importers in the EU and is going to be pretty tough as it comes up. 

The Battery Regulations establishes legally binding requirements across the entire battery life cycle, including mandatory due diligence for companies placing batteries on the EU market.

These companies must conduct due diligence on the social and environmental risks in their supply chains, aligned with the OECD framework. Specific thresholds for carbon footprint disclosure and minimum recycled content requirements for key battery materials such as cobalt, lead, lithium and nickel. Stringent traceability and chain of custody requirements for battery supply chains, setting it apart from broader due diligence laws. For example, it mandates digital battery passports for electric vehicle industrial and rechargeable batteries over two kilowatt per hour. In this respect, the regulation goes beyond voluntary standards by making traceability legally enforceable and integrating circular economy principles.

Another key difference is that unlike broader due diligence laws like the EU Corporate Sustainability Due Diligence Directive, or the CSDDDD, of known, and the EU Conflict Minerals Regulation, the battery's regulation is product-specific rather than company-wide. The regulation therefore seeks to reinforce the EU's commitment to sustainable supply chains under the Green Deal with the intention to level the playing field for companies operating within the region.

Now, that's a lot to digest in a short time. So James, what do companies need to do?

Well, pretty simple. You need to conduct due diligence in your supply chain on the four raw materials in scope of the regulation. And of course, these include lithium, nickel, coal, and graphite and their compounds, the battery active materials. Now there are 15 environmental, social and human rights risks which are identified within the regulation, and these have got to be considered within the due diligence. But those are not exhaustive.

The regulation encourages you to think more broadly than just those named risks so in practice, this means that due diligence and traceability need to go hand in hand. On the slide that you can see here, there are articles 49 to 52 of the Batteries Regulation, which specify eight requirements for management systems and processes that companies need adopt to be compliant.

Four of these requirements on the left-hand side here you can see they cover things that you need to have in place within a due diligence management system and this of course includes a policy, it includes making sure that you've got adequate oversight and responsibility for due diligence, it means also putting in place a system of controls and then encouraging transparency. It also includes an adequate grievance mechanism as well and this is something remains quite a key gap for most companies.

Now on the right-hand side the second set of requirements here all relate to processes, and this includes the assessment and response to risks in the battery supply chain, the third party verification of your due diligence process by a notified body and of course then the reporting requirements that you have. 

So, in order to break this down let's have look at how each of these eight requirements lead up to August this year and to do so we'll break it into a roadmap as you can see on the screen. This is a road map of typical activity to follow to achieve compliance and again as Yue Jin was saying it looks like it can be a lot at first particularly given the August timeline but the reality is that most companies will have many of these items in progress already so some of the things that you can see there in terms of establishing the policies we talked about already but a key other item is about building awareness and capacity both within the business but also within the supply chain itself.

In terms of ongoing activities of course due diligence is one of those it's an ongoing process as is developing those risk response plans and monitoring those risk responses and then of course getting ready for the annual reporting that's required under the Batteries Regulation as well. But let's zoom in now on three of these activities and look at what's required in more detail. Yue Jin?

Thanks, James. First, map the supply chain and complete initial risk scoping. This is an early-stage activity that companies should prioritize so that they know what suppliers are in scope of due diligence requirements.

Secondly, establish a chain of custody controls underpinned by material traceability. This underpins your map supply chain with actual relevant flows of material.

Third, conduct progressively in-depth due diligence based on what is happening in your supply chain, and the material flows through your supply chain. What do we mean by material traceability?

The IEA, the International Energy Authority, and the OECD have published a comprehensive report on traceability in critical mineral supply chains very recently, back in February. It defines traceability as the ability to track four specific types of information. Firstly, the product's origin, that is, the location where the product was originally mined, manufactured, or produced. The product's geographical path, that is, the various locations where the product underwent some form of transformation or through which it transited. Thirdly, the product's chain of custody, that is to say the sequence of entities that help ownership or control over the product throughout the supply chain. And fourth, the product's physical evolution, that is the product's different stages of processing and transformation.

You can see on the next slide an illustration of what leading companies and their supply chains are doing with the help of technology. Each actor in the supply chain is connected and providing ongoing traceability data. To enable supply chain traceability, it is necessary to have sufficient clarity and certainty of the flow of materials through the end-to-end supply chain from source to manufacturer.

A key learning from six years of working with OEM customers is that participants in the supply chain is dynamic. It doesn't stand still. It is constantly changing. Chemistry's change, spot purchasing is common, especially when commodity prices fall, and midstream participants are driven by availability and price. Your due diligence is only as good as your knowledge of who is actually doing what in your supply chain.

Moreover, it's impossible for a range of other regulatory obligations to comply with other regulatory obligations without knowing exactly who is in your supply chain at all times for every import. As James mentioned earlier, due diligence and traceability need to go hand in hand.

Thanks, Yue Jin. So let's now look then at what businesses are doing as they prepare for compliance. And to do this, we thought it would be useful to show some examples of three different types of companies at different stages of maturity to see how they're preparing.

Now, the examples we've got are fictitious, but they are based on what we've seen in similar companies at these maturity levels. So starting on the left-hand side, Company A, which is Alpha Storage Solutions. This company is an OEM that manufactures and supplies battery products to European companies for energy storage and data centres.

Now, Alpha Storage is at the very early stages of its maturity and responsible sourcing, particularly with a limited supply chain and not having previously been in scope of due diligence regulations. Therefore, this company's pretty much at the start of its compliance journey for the regulation and is addressing gaps in its due diligence approach very quickly. At the same time, though, it has scoped much of what it's included in its supply chain in the four materials in scope of the regulation it's identified a limited number of suppliers and is now prioritizing the risk scoping of these. As a result, the company's found that its due diligence requirements are much more manageable than first thought, but it's still got quite a bit of work to do to develop its management system where there are key gaps in policy and grievance mechanisms.

On the right-hand side, you can see Company C, which is Cosmos online. Now Cosmos is at the other end of the maturity scale. The company sells the party goods in the European market, including electronic items containing batteries. And it also places its own branded products on the market as well. It's got a very mature sustainability program, but with thousands of third party suppliers and manufacturers due diligence under the batteries regulation is a big challenge in terms of scope and resources for the company. So to make due diligence more manageable, the companies developed a prioritized model for due diligence. 

And this, of course, is in line with the OECD guidelines for multinational enterprises, which encourage companies with large chains to identify general areas where the risk of adverse impacts is most significant, and then to prioritize these. So the company's already mapped its supplier universe is now completing a risk scoping exercise to find out the country, the sector, the product and the raw material specific risks to help it further prioritise. It's also focusing on what we call so-called choke points within the supply chain to make sure it concentrates its efforts below its direct suppliers. Now choke points are where the number of suppliers is low, typically where batteries are produced or battery raw materials are refined and processed. And by taking this approach, Cosmos can channel its due diligence and traceability efforts, especially where the upstream raw material chain is complex.

In the middle of the maturity scale is BetaCars. This is an automotive OEM, which has identified its upstream critical minerals supply chain in collaboration with its tier 1 suppliers. Based on this initial supply chain map, it actively assesses due diligence risk of each of these suppliers using OECD-based assessments. 

On the back of these assessments, the OEM will take risk-based decisions to optimize the participants that are in their supply chain. They then onboard in conjunction, onboard each supply chain actor to implement a solution for ongoing provision of material traceability data to ensure that the raw materials did originate and flow through the expected sources across the supply chain. The traceability solution tracks and verifies the flows of material and flecks alerts where the expected traceability data or material flows does not comply with what is expected. 

Beyond the EU Batteries Regulation: Tackling global regulatory complexity with supply chain due diligence

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