Obligations of economic operators concerning battery due diligence policies (Omnibus IV)

ECOS welcomes the opportunity to provide feedback on the European Commissions proposal to postpone the application date of the battery due diligence obligations under Regulation(EU)2023/1542 from 18 August 2025 to 18 August 2027. While ECOS acknowledges the challenges mentioned in the proposal, a full two-year postponement risks undermining the regulations' objectives.

Ministry of Economy, Trade and Industry of Japan welcomes the European Commissions proposal to postpone the due diligence obligations under the Battery Regulation as a necessary step to ensure its effectiveness.

While TCS is not generally in favour of postponing the implementation of sustainability-related policies, in this case we support the proposed delay of the battery due diligence obligations under the Batteries Regulation.

Circularise is a technology company advancing the circular economy by enabling traceability and secure data exchange across complex global supply chains. Our Digital Product Passports (DPPs) support companies in tracking critical product information such as carbon footprint, material composition, and origin, ensuring interoperability, data privacy, and supply chain accountability in, among others, the battery…

The Würth Group welcomes the European Commission’s proposal to postpone the application of the battery due diligence obligations under Regulation (EU) 2023/1542 by two years. In our view, this extension is necessary and useful in order to give companies sufficient time to adapt their internal processes, supply chain structures and information flows to the new requirements.

Filed in German · English published by the European Commission

SEMI Europe, representing 3000+ global and 300+ European companies in the microelectronics supply chain, welcomes the opportunity to comment on the proposed delegated regulation under the EU Battery Regulation (EUBR).

TIC Council agrees with the European Commissions assessment that a timely application of the due diligence obligations is unfeasible under the current conditions. However, rather than postponing the obligations, efforts should have focused on addressing the underlying implementation failures that have made timely application difficult.

LG Energy Solution Wrocław sp. z o.o. presents the position as regards the Regulation (EU) 2025/1561 of the European Parliament and of the Council amending Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies. Please see enclosed the file.

The Japan Business Council in Europe (JBCE) appreciates the European Commissions proposals to amend the EU Batteries Regulation (EUBR) via Omnibus package IV. We hereby submit our comments on the amendments concerning battery due diligence obligations, along with suggestions to further rationalise the administrative burden in accordance with proportionality.

LEVA-EU is the only trade association in the EU to represent businesses in the sector of Light Electric Vehicles, i.e. all electric vehicles which are either included in Regulation 168/2013 or excluded from the Regulation. Most of these vehicles have batteries that belong to the LMT battery-category. We agree with the Commission Proposal for a Regulation (COM(2025)258) aimed at postponing due diligence requirements.

We, Japanese 4 electric and electronic industry associations-JEMA, JEITA, CIAJ and JBMIA (hereinafter JP4EE) welcome the opportunity to provide our comments and proposals on the draft Commission Regulations under the Omnibus IV Simplification Package.

EGMF and FEM welcome the publication of the European Commission's Amending Regulation as regards the obligations of economic operators concerning battery due diligence policies. The proposed amendments provide economic operators and third-party verification bodies with the necessary additional time for fulfilling due diligence processes.

The European Power Tool Association (EPTA) welcomes the opportunity to provide feedback on the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies. Please find our comments in the enclosed position paper.

Cobalt Institute's response includes the following: Support retaining certain aspects and delaying the timelines we are pleased the Commission has decided not to reopen the core due diligence obligations laid out in Chapter VII of the Batteries Regulation, and delay implementation by two years. This provides companies with the certainty and time needed to meet the reporting requirements.

Tokyo Electron Limited, TEL, is one of the largest semiconductor manufacturing equipment suppliers delivering state-of-the-art machinery to the EU market. TEL fully supports the objectives of the EUBR Due Diligence requirements in ensuring responsible sourcing and supply chain management.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposal to postpone the battery due diligence obligations under the EU Batteries Regulation.

We, the Battery Association of Supply Chain (BASC), are an organization dedicated to contributing to the sustainable development of the battery supply chain, encompassing materials and components. Our aim is to support the battery industry through policy recommendations and providing input on international regulations.

We welcome the Commissions decision to delay the implementation of Chapter VII of the Batteries Regulation by two years. This pause is essential to finalise key elements such as implementation guidelines, the designation of notifying authorities by member states, and alignment with the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

Tobacco Europe welcomes the opportunity to provide input on the proposed postponement of due diligence obligations under the Batteries Regulation. In our contribution attached, we highlight two key points we believe are essential for a proportionate and effective implementation: (1) the timely publication of implementing guidelines, and (2) the need for clarification on scope and thresholds.

CEMA, representing the European agricultural machinery industry, with large multinational companies but also numerous European SMEs active in the sector, welcomes the proposed postponement by (at least) two years of the battery due diligence requirements and asks for a quick adoption to ensure legal certainty for economic operators.

NGK INSULATORS, LTD. (NGK) welcomes the decision to postpone the implementation of Chapter VII of the Batt. Regulation, which outlines the due diligence obligations. NGK recognizes the importance of due diligence obligations, which require companies to establish comprehensive systems for risk assessment, mitigation of potential adverse impacts, and monitoring the flow of critical raw materials.

Please find attached the feedback from the German Association of the Automotive Industry e.V. The German Association of the Automotive Industry (VDA) consolidates around 620 manufacturers and suppliers under one roof. The members develop and produce cars and trucks, software, trailers, superstructures, buses, parts and accessories as well as new mobility offers.

The European Automobile Manufacturers' Association (ACEA) recognises the European Commissions proposal to postpone the due diligence obligations under the EU Batteries Regulation (EUBR). We understand that this delay is a pragmatic and necessary measure to ensure that manufacturers and relevant authorities can meet the Regulations objectives effectively.

RECHARGE, the voice of the advanced rechargeable and lithium batteries value chain in Europe, and EUROBAT, the association for European automotive and industrial battery manufacturers, together with Eurometaux, the voice of non-ferrous metals producers and recyclers in Europe, would like to support to the European Commission proposal for a regulation (COM(2025)258) postponing the due diligence obligations under the…

Eurometaux, the voice of non-ferrous metals producers and recyclers in Europe together with EUROBAT, the association for European automotive and industrial battery manufacturers, and RECHARGE, the voice of the advanced rechargeable and lithium batteries value chain in Europe, would like to support to the European Commission proposal for a regulation (COM(2025)258) postponing the due diligence obligations under the…

EUROBAT, the association for European automotive and industrial battery manufacturers, together with RECHARGE, the voice of the advanced rechargeable and lithium batteries value chain in Europe, and Eurometaux, the voice of non-ferrous metals producers and recyclers in Europe, would like to support to the European Commission proposal for a regulation (COM(2025)258) postponing the due diligence obligations under the…

BASF Stationary Energy Storage welcomes the decision to postpone the implementation of Chapter VII of the Batt. Regulation, which outlines the due diligence obligations. (BSES) recognizes the importance of due diligence obligations, which require companies to establish comprehensive systems for risk assessment, mitigation of potential adverse impacts, and monitoring the flow of critical raw materials.

Finnwatch finds it regretful that the Commission proposes to delay the implementation of battery due diligence obligations. When the Commission once again starts to roll back on legislation that has been so recently adopted that it has not yet even been implemented, it creates uncertainty and undermines democracy and the EUs reliability and credibility.

The TÜV Association welcomes the opportunity to provide feedback on the proposed postponement of battery due diligence obligations for economic operators. While we share the Commission's view that a timely application of the due diligence obligations is not realistic under the current framework conditions, we would like to stress that the designation of notifying authorities by EU Member States is a structural…

The BMW Group welcomes the proposed postponement of the battery due diligence requirements and asks for a quick adoption. The postponement of the Battery Regulation due diligence obligations by two years is a necessary measure to give authorities enough time to appoint the required notified bodies and to finalize the urgently needed implementation guidelines in due time.

The European DIY Retail Association (EDRA) is the voice for the home improvement industry in Europe. Today EDRA represents 140 home improvement companies in Europe either through its country associations or as direct members.

The current approach appears to base the applicability of obligations solely on the size of the company. It would be helpful to clarify whether this was the intended outcome. Requiring a large company to comply fully with all regulatory obligationseven in cases where it places only a minimal number of primary batteries in a productmay lead to disproportionate administrative and compliance burdens.

Both the initial EU Battery Regulation Chapter VII and Proposal to amend EU Battery Regulation include only EUR limits for net turnover of a company or a group of consolidated companies. A company or group may operate in multiple business areas exceeding the turnover limit, but batteries placed in EU market may be only small portion of their turnover. Still, they are obliged to fullfil due diligence obligations.

The DigitalTrade4.EU consortium welcomes the European Commissions proposal to postpone battery due diligence obligations to August 2027. This response advocates leveraging the delay to build a resilient digital framework centered on Digital Product Passports (DPPs), ensuring supply chain transparency and regulatory alignment with EU Green Deal goals.