This guide provides practical implementation guidance for companies subject to the EU Battery Regulation's cobalt-specific requirements. It covers the due diligence obligations (Articles 48–52), carbon footprint declaration (Article 7), recycled content requirements (Article 8), and battery passport preparation (Article 77).
Step 1: Due Diligence Policy (Deadline: August 2025)
Develop and adopt a cobalt supply chain due diligence policy that: references the OECD Due Diligence Guidance; covers cobalt, lithium, nickel, and natural graphite; assigns management responsibility; includes supplier engagement and audit requirements; and is publicly available on your website.
Step 2: Supply Chain Mapping
Map your cobalt supply chain to the smelter/refiner level. For each battery model, identify: the cobalt content (kg per battery); the smelters and refiners supplying cobalt to your cell manufacturers; the countries of cobalt origin; and the proportion of ASM vs. large-scale mining cobalt.
Step 3: Carbon Footprint Declaration (Deadline: February 2025 for EV batteries)
Calculate the carbon footprint of cobalt across the battery lifecycle using the EU methodology (Commission Regulation implementing Article 7). The cobalt mining and processing stage typically accounts for 15–25% of total battery carbon footprint. Engage your cobalt suppliers for primary emissions data; use EU default values where primary data is unavailable.
Step 4: Recycled Content Tracking
Establish a system to track and declare the percentage of recycled cobalt in each battery model. From 2027, you must declare recycled cobalt content. From 2031, EV batteries must contain at least 6% recycled cobalt. Engage secondary cobalt suppliers and recyclers to obtain chain-of-custody documentation for recycled content.
Step 5: Battery Passport Preparation (Deadline: 2027)
Prepare for the digital battery passport requirement by: selecting a battery passport platform (several industry consortia are developing standards); defining the data model for cobalt-related passport fields; establishing data collection processes from your supply chain; and testing QR code generation and data accessibility.