JBCE Position Paper on the Due Diligence Obligations under the EU Batteries Regulation

The Japan Business Council in Europe (JBCE) has published a position paper in response to the amendments to the EU Batteries Regulation (Regulation (EU) 2023/1542) concerning due diligence obligations, proposed under the Omnibus Package IV.

In this paper, JBCE welcomes the two-year postponement of the application of due diligence obligations. However, to ensure that economic operators have sufficient preparation time, JBCE strongly calls for a further extension of the deadline to 18 August 2028.

JBCE's main recommendations include:

• Early release of the draft due diligence guidelines, timely designation of Notified Bodies and further extension of the deadline.
• Ensuring regulatory coherence and alignment for simplified implementation of due diligence obligations under the Batteries Regulation with other EU due diligence frameworks such as the CS3D, EUDR, and FLR.
• Call for the timely recognition and implementation of effective industry schemes and balanced transparency.
• Establishment of a robust implementation infrastructure.

JBCE reaffirms its support for the objectives of the Batteries Regulation, which promotes responsible sourcing and sustainable supply chains, and calls for a practical and realistic implementation framework.