Traceability and Certification in Mineral Supply Chains
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Traceability rules now require buyers to document where minerals come from and, in some cases, to have it checked by a third party. The EU Batteries Regulation requires an electronic battery passport for each electric vehicle battery, each industrial battery over 2 kilowatt-hours and each light means of transport battery from 18 February 2027, and battery supply chain due diligence on cobalt, natural graphite, lithium and nickel from 18 August 2027. In the United States, importers must prove by clear and convincing evidence that goods linked to Xinjiang were not made with forced labor.
18 Feb 2027
date from which EV batteries and industrial batteries over 2 kWh need an electronic battery passport in the EU
18 Aug 2027
start of EU battery due diligence, postponed from 18 August 2025
Source: Regulation (EU) 2025/1561
1 Jan 2021
date from which EU importers of tin, tantalum, tungsten and gold must carry out supply chain due diligence
Source: Regulation (EU) 2017/821
Clear and convincing
evidence standard a U.S. importer must meet to rebut the Xinjiang forced labor presumption
What do the main traceability rules require?
The rules differ in what they make buyers trace and who checks it. The table summarises the instruments that were read in the legal texts or agency pages.
| Rule | What must be traced or reported | Who verifies | Date |
|---|---|---|---|
| EU Batteries Regulation: battery passport (Article 77) | An electronic record for each battery covering model and individual battery information, with public, authority-only and legitimate-interest access levels. | Information set out in Annex XIII is accessible to the public, to notified bodies, market surveillance authorities and the Commission, and to persons with a legitimate interest. | From 18 February 2027 |
| EU Batteries Regulation: due diligence | Social and environmental risks in the extraction, processing and trading of cobalt, natural graphite, lithium and nickel used in batteries; the policy should follow internationally recognised standards such as the OECD Due Diligence Guidance. | Third-party verification by notified bodies; Commission-recognised due diligence schemes may help. | From 18 August 2027 (postponed from 2025) |
| EU Conflict Minerals Regulation 2017/821 | Supply chain due diligence for importers of tin, tantalum, tungsten and gold above annual volume thresholds, with a published list of responsible smelters and refiners. | Member state competent authorities. | Importer duties from 1 January 2021 |
| U.S. conflict minerals disclosure (15 U.S.C. 78m(p)) | Whether conflict minerals originated in the Democratic Republic of the Congo or an adjoining country. | Independent private sector audit where they did. | In force |
| U.S. Uyghur Forced Labor Prevention Act | Goods made wholly or partly in Xinjiang or by listed entities are presumed barred; importers must show where goods came from and that no forced labor was involved. | U.S. Customs and Border Protection reviews and can detain shipments; importers must answer information requests fully. | From 21 June 2022 |
| EU corporate sustainability due diligence | Adverse human rights and environmental impacts in companies' chains of activities. | Member state supervisory authorities. | Postponed to 26 July 2029 |
Sources: Regulation (EU) 2023/1542, Regulation (EU) 2025/1561, Regulation (EU) 2017/821, 15 U.S.C. 78m, CBP and Directive (EU) 2026/470.
Why did the EU delay battery due diligence?
The EU delayed battery due diligence because the verification system was not ready. The postponing regulation says designation of the notified bodies that must verify compliance was taking longer than expected, and that due diligence schemes for the raw materials in batteries still had to be developed and recognised by the Commission. Manufacturers also needed time to analyse and adjust supply chains. The Batteries Regulation itself notes that the conflict minerals regulation does not cover minerals used in battery production.
What does a certificate or audit prove?
An audit or certificate proves that a process was followed, not that every tonne is clean. The U.S. disclosure rule asks for an independent private sector audit of a company's due diligence, the EU battery rules call for third-party verification, and the EU conflict minerals system relies on a list of responsible smelters and refiners. For the pressure that drives these rules, see sanctions and compliance.
Frequently asked questions
What is a battery passport?
A battery passport is an electronic record for a battery that holds information on the battery model and the individual battery. From 18 February 2027 the EU requires one for each electric vehicle battery, each industrial battery with a capacity above 2 kilowatt-hours and each light means of transport battery.
When does EU battery due diligence apply?
Battery due diligence on cobalt, natural graphite, lithium and nickel applies from 18 August 2027 under Regulation (EU) 2025/1561, which moved the date from 18 August 2025. The regulation gives delays in designating verifying bodies and in developing recognised schemes as reasons.
Which minerals are covered by EU conflict minerals rules?
Tin, tantalum, tungsten and gold, in ores and as metals, above annual import volume thresholds. For example, the thresholds are 5,000 kilograms of tin ore, 250,000 kilograms of tungsten ore and 100 kilograms of unwrought gold.
What must importers show under the Uyghur Forced Labor Prevention Act?
Importers must show by clear and convincing evidence that goods linked to Xinjiang or to listed entities were not mined, produced or manufactured wholly or in part by forced labor, and must respond completely to CBP requests for information. The presumption has applied since 21 June 2022.
Sources
Read on October 13, 2026. Figures on this page come from these documents; where a number is an estimate, the source says so.
- Regulation (EU) 2023/1542 (Batteries Regulation), Article 77 and recitals 81 to 83. Read on EUR-Lex
- Regulation (EU) 2025/1561 (postponing battery due diligence). Read on EUR-Lex
- Regulation (EU) 2017/821 (Conflict Minerals Regulation), Article 1 and Annexes. Read on EUR-Lex
- U.S. Customs and Border Protection: Uyghur Forced Labor Prevention Act
- 15 U.S.C. 78m (conflict minerals disclosure, subsection p)
- Directive (EU) 2026/470. Read on EUR-Lex
