Home›Guides›Cobalt Supply Chain Due Diligence Checklist

This checklist provides a structured approach to cobalt supply chain due diligence aligned with the OECD Due Diligence Guidance, EU Battery Regulation (Articles 48–52), and UFLPA requirements. It is designed for battery manufacturers, EV producers, electronics companies, and any business with cobalt in its supply chain.

Phase 1: Policy and Governance

  • ☐ Adopt a written cobalt supply chain due diligence policy referencing the OECD Guidance
  • ☐ Assign senior management responsibility for supply chain due diligence
  • ☐ Integrate due diligence into supplier contracts and procurement policies
  • ☐ Establish a grievance mechanism for supply chain concerns
  • ☐ Define escalation procedures for identified risks

Phase 2: Supply Chain Mapping

  • ☐ Map cobalt supply chain from product to smelter/refiner level
  • ☐ Identify all cobalt-containing components and materials
  • ☐ Collect Cobalt Reporting Templates (CRT) from direct suppliers
  • ☐ Identify all smelters and refiners in the supply chain
  • ☐ Verify refiner identity against RMI CoRAP conformant refiner list
  • ☐ Identify country of cobalt origin for each refiner

Phase 3: Risk Assessment

  • ☐ Assess each sourcing country against OECD Annex II red flags
  • ☐ Identify DRC-sourced cobalt and apply enhanced due diligence
  • ☐ Screen all suppliers against UFLPA entity list (quarterly)
  • ☐ Identify any Xinjiang-based processing steps
  • ☐ Assess ASM vs. large-scale mining mix for DRC cobalt
  • ☐ Review third-party audit reports for identified smelters/refiners

Phase 4: Risk Mitigation

  • ☐ Engage suppliers on identified risks with time-bound improvement plans
  • ☐ Prioritise CoRAP-conformant refiners in procurement decisions
  • ☐ Support ASM formalisation initiatives (Fair Cobalt Alliance, RCI)
  • ☐ Suspend or discontinue engagement with suppliers where risks cannot be mitigated
  • ☐ Participate in industry-wide initiatives (RCI, GBA, IRMA)

Phase 5: Reporting

  • ☐ Publish annual due diligence report (OECD Step 5)
  • ☐ Prepare EU Battery Regulation due diligence documentation (from Aug 2025)
  • ☐ File SEC Form SD if applicable (Dodd-Frank 1502)
  • ☐ Report on CSDDD value chain due diligence (from 2027–2029)
  • ☐ Maintain import documentation for UFLPA CBP review