Compliance for Battery Raw Materials · Regulation (EU) 2023/1542
Your obligations on battery raw materials, measured theme by theme and translated into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Compliance for Battery Raw Materials · Regulation (EU) 2023/1542
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2023/1542 of 12 July 2023 concerning batteries and waste batteries assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, one level, the level above, and the action linking the two, that turns an observation into a trajectory.
Is your supply chain for cobalt, lithium, nickel and natural graphite mapped beyond direct suppliers?
- N1
No mapping. Only direct suppliers and purchased references are known.
- N2
Mapping has begun on a few references. It is partial, held in a standalone file, and has not been updated since it was created.
- N3
Smelting and refining sites are identified for the majority of volumes of the four materials. The mapping is updated at a defined and documented frequency.
- N4
The mapping covers all volumes, traces back to extraction sites for high risk flows, and feeds directly into risk scoring and purchasing decisions.
- N5
Data is reconciled against volumes declared by suppliers, checked by on site sampling, and reviewed alongside third party verification findings.
Action to move from L2 to L3
Send each direct supplier of the four materials a formal request to declare their smelting and refining sites, add it to the annual requalification questionnaire, and rule on non responses at the following quarter’s procurement committee.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2023/1542 replaces Directive 2006/66/EC and covers the full battery life cycle, from raw material extraction to end of life. On the upstream side, it targets four materials: lithium, cobalt, nickel and natural graphite. Operators concerned must adopt a due diligence policy, map their supply chain, assess the social and environmental risks linked to extraction and processing sites, have this system verified by a third party, and publish it. Added to this are the carbon footprint declaration, minimum recycled material content, and the battery passport.
Managing this gets harder as soon as you move past the text. The relevant information sits with tier 2 or tier 3 suppliers, often outside the European Union, and the graphite or refined cobalt chain is hard to read from a purchase order. Three questions keep coming up: can you name the smelting and refining sites present in your flows, or only your direct suppliers? Do your contractual clauses actually allow you to demand data and an audit at your supplier’s supplier? Who in the organisation decides when an identified risk requires suspending a supply source?
One confusion is worth clearing up: the Battery Regulation is not an extension of Regulation (EU) 2017/821 on conflict minerals. The scope of materials differs, so does the triggering event, and battery due diligence covers a broader spectrum of risks than conflict financing, including water, air, biodiversity, labour and neighbouring communities. Companies already organised around tin, tantalum, tungsten and gold have a reusable methodological base, not a system that transfers as is. Regulation (EU) 2024/1252 on critical raw materials adds a supply security logic that intersects the same flows.
A compliance audit answers yes or no: the policy exists, third party verification has taken place, the declaration is published. A maturity assessment answers differently. It places each practice on a progressive scale, distinguishes the written procedure from the applied procedure, and points to the precise action that moves it up a level. This is what allows you to decide what must be handled before the next deadline and what belongs to the two year transformation programme.
Within Datamensio, the framework is ready to use. You can adapt it to your value chain: the AI adjusts the themes, rephrases questions according to your position in the supply chain (extraction, refining, cell manufacturing, pack assembly) and refines the levels, or builds a variant from your own procedures and purchasing contracts.
Reference standard: Regulation (EU) 2023/1542 of 12 July 2023 concerning batteries and waste batteries
The themes assessed
Due diligence policy
Existence of a formalised and approved policy, scope of materials covered, alignment with OECD principles, internal dissemination and publication, roles and decision making body.
Supply chain mapping
Identification of direct and indirect suppliers, extraction, smelting and refining sites, depth achieved, update frequency, handling of untraceable flows.
Risk identification and assessment
Risk categories covered (water, air, soil, biodiversity, labour, communities, corruption), scoring method, information sources used, prioritisation of sensitive sites.
Mitigation measures and supplier engagement
Contractual clauses and audit rights, improvement plans with suppliers, suspension or disengagement criteria, escalation to leadership.
Traceability and chain of custody
Batch tracking system, accompanying documents, record retention, reconciliation of incoming and outgoing volumes, management of mixed sources.
Battery carbon footprint
Calculation boundary, quality of upstream data, allocation rules, preparation of the declaration and performance class, verification of supplier data.
Recycled content in cobalt, lithium, nickel and lead
Identification of secondary material flows, evidence on recovery rates, contracting with recyclers and refiners, preparation of the calculation and its verification.
Battery passport and transparency
Data to be included in the passport, availability and reliability of upstream information, collection responsibilities, coordination with labelling and marking.
Third party verification and evidence governance
Preparation for verification, handling of findings, correction plan, retention of reports, reporting to the board and annual publication.
Reporting mechanism and continuous improvement
Alert mechanism accessible to third parties and workers across the chain, handling of reports, lessons learned, periodic review of the system.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does the assessment count as proof of compliance with the Battery Regulation?
No. The regulation requires verification of the due diligence system by a notified third party body. Datamensio measures the maturity of your practices, documents gaps, and produces the action plan that prepares you for that verification. It does not issue any certificate.
How is this different from a compliance audit?
An audit concludes with a gap or a pass on a given requirement. The assessment places the practice on five levels and points to the action that moves it up a level. The two complement each other: the assessment prepares and prioritises, the audit validates.
How long does the assessment take?
The short version can be completed in a single working session. The full version involves procurement, HSE and compliance working together, and typically takes one to two weeks, with most of the time spent gathering evidence from suppliers and sites.
Can the framework be adapted to our position in the supply chain?
Yes. Questions, levels and themes can be modified, and the AI generates a variant specific to extraction, refining, cell manufacturing or pack assembly based on your procedures. You retain full control of the framework.
Can we reuse our conflict minerals system?
Partly. The mapping method and risk governance can be reused. The scope of materials and the range of risks differ: the Battery Regulation also covers water, air, biodiversity, labour and communities. A cross cutting roadmap allows both texts to be addressed without duplicating actions.
How do you compare multiple sites or business units?
Each entity is assessed against the same framework, which makes scores comparable by theme. The benchmark places each site against the others and against its own history, and action plans are consolidated into a group level roadmap.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European solutions.