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• This Navigator provides an online, step-by-step guide to 5 key EU laws related to supply chain diligence. It helps users determine if their operations might be affected by these laws.
• This Navigator covers the Directive (EU) 2024/1760 on corporate sustainability due diligence (the Corporate Sustainability Due Diligence Directive or CSDDD), Regulation (EU) 2023/1542 concerning batteries and waste batteries (the EU Batteries Regulation or EUBR), Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market (the EU Forced Labour Regulation or EUFLR), Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas (the EU Conflict Minerals Regulation or EUCMR) and Regulation (EU) 2023/1115 on deforestation-free products (the EU Deforestation Regulation or EUDR). This is not an exhaustive list of EU or national laws which may apply.
• White & Case is a global law firm with market-leading Regulatory and Compliance and Sustainability and Responsible Business practices. Managing legal risk arising from supply chain is emerging as a critical consideration, and we advise companies worldwide on how to manage this global challenge.

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To obtain legal advice and specific analysis regarding EU sustainability regulations, please contact one of our specialists:

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

Last updated on November 11, 2025.

What is "placing" on the EU market?

'Placing a product on the EU market' means the being the first person to 'make available' the specific product on the EU market. For example, the first time it is marketed or supplied for distribution, consumption or use in the EU in the course of a commercial activity, whether in return for payment or free of charge.

What is "making available on the EU market"?

'Making available' a product on the EU market means is any supply of a relevant product for distribution, consumption or use on the EU market during the course of a commercial activity, whether in return for payment or free of charge.

"In the course of a commercial activity" means for the purpose of processing, for distribution to commercial or non-commercial consumers, or for the company's own use.

This covers "importers" to the EU market, which the regulation defines as any natural or legal person or association of persons established within the Union who places a product from a third country on the Union market.

What is an "exporter"?

An "exporter" is:

• The person established in the customs territory of the Union who, at the time when the declaration is accepted, holds the contract with the consignee in the third country and has the power for determining that the goods are to be brought to a destination outside the customs territory of the Union,
• The private individual carrying the goods to be exported where these goods are contained in the private individual's personal baggage,
• In other cases, the person established in the customs territory of the Union who has the power for determining that the goods are to be brought to a destination outside the customs territory of the Union.

What is "placing" on the EU market?

'Placing a product on the EU market' means the being the first person to 'make available' the specific product on the EU market. For example, the first time it is marketed or supplied for distribution, consumption or use in the EU in the course of a commercial activity, whether in return for payment or free of charge.

What is "making available on the EU market"?

'Making available' a product on the EU market means is any supply of a relevant product for distribution, consumption or use on the EU market during the course of a commercial activity, whether in return for payment or free of charge.

"In the course of a commercial activity" means for the purpose of processing, for distribution to commercial or non-commercial consumers, or for the company's own use.

This covers "importers" to the EU market, which the regulation defines as any natural or legal person or association of persons established within the Union who places a product from a third country on the Union market.

What is an "exporter"?

An "exporter" is:

• The person established in the customs territory of the Union who, at the time when the declaration is accepted, holds the contract with the consignee in the third country and has the power for determining that the goods are to be brought to a destination outside the customs territory of the Union,
• The private individual carrying the goods to be exported where these goods are contained in the private individual's personal baggage,
• In other cases, the person established in the customs territory of the Union who has the power for determining that the goods are to be brought to a destination outside the customs territory of the Union.

Based on your responses:

CSDDD

The activities of your business most likely fall within the scope of the Corporate Sustainability Due Diligence Directive (CSDDD). It is advisable to seek confirmation against the text in force.

The CSDDD entered into force on 25 July 2024 with staggered implementation for different categories of companies. On 14 April 2025, the CSDDD was amended to extend the compliance deadline for the first wave of companies (those with over 5,000 employees and €1.6 billion in net turnover) by one year to July 2028. The CSDDD imposes a due diligence duty on companies, to identify and address adverse human rights and environmental impacts – whether potential or actual - caused by their operations, subsidiaries and/or business relationships. In-scope companies must also put into effect a climate change transition plan in line with the 2050 climate neutrality goal under the Paris Agreement.

Current status: The substantive requirements of the CSDDD are currently being reviewed by the European Parliament and Council as part of the so-called 'Omnibus' package published by the European Commission on 26 February 2025, aimed at simplifying reporting requirements. It is important to monitor any amendments to the CSDDD.

National laws of the EU's member states may impose additional obligations, for example Germany's Lieferkettengesetz (LkSG) and France's Loi de Vigilance.

EUFLR

Your business activities may fall within the scope of the EU Forced Labour Regulation, which prohibits any goods produced using forced labour from being made available in the EU market or exported from the EU.

Enforcement by competent authorities is in two stages. First, the authority will investigate if there is a substantiated concern that the product in the supply chain is made using forced labour. They will consider the Commission's database of forced labour risk countries, public reports relating to forced labour, and any risk identified through the company's own due diligence processes in relation to products produced using forced labour.

If a substantiated concern is found, the authority may open a formal investigation into whether in fact the products were produced using forced labour. If this is confirmed, the authority will issue a declaration that the products are made with forced labour and prohibited from being placed on the EU market. At this stage, customs authorities may block and detain products, order disposal, and, in some circumstances, prohibit access to the EU market.

If you have any questions, please contact one of our specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

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Based on your responses:

CSDDD

The activities of your business most likely fall within the scope of the Corporate Sustainability Due Diligence Directive (CSDDD). It is advisable to seek confirmation against the text in force.

The CSDDD entered into force on 25 July 2024 with staggered implementation for different categories of companies. On 14 April 2025, the CSDDD was amended to extend the compliance deadline for the first wave of companies (those with over 5,000 employees and €1.6 billion in net turnover) by one year to July 2028. The CSDDD imposes a due diligence duty on companies, to identify and address adverse human rights and environmental impacts – whether potential or actual - caused by their operations, subsidiaries and/or business relationships. In-scope companies must also put into effect a climate change transition plan in line with the 2050 climate neutrality goal under the Paris Agreement.

Current status: The substantive requirements of the CSDDD are currently being reviewed by the European Parliament and Council as part of the so-called 'Omnibus' package published by the European Commission on 26 February 2025, aimed at simplifying reporting requirements. It is important to monitor any amendments to the CSDDD.

National laws of the EU's member states may impose additional obligations, for example Germany's Lieferkettengesetz (LkSG) and France's Loi de Vigilance.

EUFLR

Your business activities do not appear to fall within the scope of the EU Forced Labour Regulation. It is advisable to check against the legal texts or to contact one of the specialists at White & Case LLP.

If you have any questions, please contact one of our specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

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Based on your responses:

CSDDD

Your business activities do not appear to fall within the scope of the Corporate Sustainability Due Diligence Directive (CSDDD). However, your activities may still fall within scope if your company is part of a group which is covered by the CSDDD. It is advisable to check against the legal texts. It is important to monitor for changes in the laws and check national laws of EU Member States which may add additional obligations. For example, Germany's Lieferkettengesetz (LkSG) and France's Loi de Vigilance may also apply.

EUFLR

Your business activities may fall within the scope of the EU Forced Labour Regulation, which prohibits any goods produced using forced labour from being made available in the EU market or exported from the EU.

Enforcement by competent authorities takes place in two steps. First, the authority will investigate if there is a substantiated concern that the product in the supply chain is made using forced labour. They will consider the Commission's database of forced labour risk countries, public reports relating to forced labour, and any risk identified through the company's own due diligence processes in relation to products produced using forced labour.

If a substantiated concern is found, the authority may open a formal investigation into whether in fact the products were produced using forced labour. If this is confirmed, the authority will issue a declaration that the products are made with forced labour and prohibited from being placed on the EU market. At this stage, customs authorities may block and detain products, order disposal, and, in some circumstances, prohibit access to the EU market.

If you have any questions, please contact one of our specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration

Based on your responses:

CSDDD

Your business activities do not appear to fall within the scope of the Corporate Sustainability Due Diligence Directive (CSDDD). However, your activities may still fall within scope if your company is part of a group which is covered by the CSDDD. It is advisable to check against the legal texts. It is important to monitor for changes in the laws and check national laws of EU Member States which may add additional obligations. For example, Germany's Lieferkettengesetz (LkSG) and France's Loi de Vigilance may also apply.

EUFLR

Your responses, your business activities do not appear to fall within the scope of the EU Forced Labour Regulation. It is advisable to check against the legal texts or to contact one of our specialists at White & Case LLP.

If you have any questions, please contact one of our specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Below are the relevant products associated with this commodity, listed in Annex I to the Deforestation Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the Deforestation Regulation, having regard to any clarification on product scope in the European Commission's Guidance Document on the EUDR.
• If necessary, please seek advice from our customs classification experts.

Relevant Products and Tariff Codes

Timber and timber products' in the EU Illegal Timber Regulation means any timber and timber products set out in the Annex to the Regulation, with the exception of timber products or components of such products manufactured from timber or timber products that have completed their lifecycle and would otherwise be disposed of as waste.

Below are the relevant products associated with this commodity, listed in the Annex to the EU Illegal Timber Regulation.

• As a first stage, identify the customs classification of your product applying the EU's Combined Nomenclature (CN code). This is an eight-digit commodity code, based on the international HS classification codes assigned to individual products traded globally. Correctly identifying the CN Code may require consultation of the relevant Explanatory Notes established under the EU Common Customs Tariff.
• As a second stage, the CN code should be checked against the product list in Annex I of the EU Illegal Timber Regulation, having regard to any clarification on product scope in the European Commission's Guidance Documents.
• If necessary, please seek advice from our customs classification experts.

Your business activities concern products that are covered by the EU Deforestation Regulation. The core obligation is that from 30 December 2025 (or 30 June 2026 for micro or small businesses), it will be prohibited to place relevant products on the EU market, or export them from the EU, unless they are 'deforestation-free'; produced in accordance with the relevant legislation of the country of production; and covered by a due diligence statement indicating no more than a negligible risk of non-compliance.

What is "deforestation free"?

"Deforestation free" means:

(a) that the relevant products contain, have been fed with or have been made using, relevant commodities that were produced on land that has not been subject to deforestation after 31 December, 2020; and

(b) in the case of relevant products that contain or have been made using wood, that the wood has been harvested from the forest without inducing forest degradation after 31 December, 2020.

Companies should consider now the impact of the EUDR on their supply chain due diligence to prepare for the new obligations that apply from 30 December 2025.

This law places distinct obligations on different types of companies, depending on their role in the supply chain for the product in question.

What is an "Operator"?

'Operators' are the companies who place relevant products on the EU market or export them. (In case the products are 'placed on the EU market' by a non-EU company, the first natural or legal person established in the Union to make such products available on the EU market shall be deemed to be an operator). Operators bear the primary responsibility for conducting a comprehensive due diligence system to verify that their products are 'deforestation-free' and comply with the legislation of the country of production.

What is "placing" on the EU market?

'Placing a product on the EU market' means the being the first person to 'make available' the specific product on the EU market. For example, the first time it is marketed or supplied for distribution, consumption or use in the EU in the course of a commercial activity, whether in return for payment or free of charge.

What is a "Trader"?

'Traders' are the downstream companies who make relevant products available on the EU market, but did not place them on the EU market for the first time. As such, the products have previously been subject to EUDR due diligence and are covered by a Due Diligence Statement. Unless they are an SME, traders should ascertain that due diligence was exercised upstream by checking the EUDR Information System, and submit their own Due Diligence Statement confirming this, without having to collect information themselves.

What is "making available on the EU market"?

'Making available' a product on the EU market means is any supply of a relevant product for distribution, consumption or use on the EU market during the course of a commercial activity, whether in return for payment or free of charge.

"In the course of a commercial activity" means for the purpose of processing, for distribution to commercial or non-commercial consumers, or for the company's own use.

This covers "importers" to the EU market, which the regulation defines as any natural or legal person or association of persons established within the Union who places a product from a third country on the Union market.

Operators and traders may mandate 'authorised representatives' to submit a due diligence statement on their behalf. In this case, the operators and non-SME traders will retain responsibility for the compliance of the relevant products.

If you have any further questions about how the EUDR obligations may apply to your company, please contact one of the regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

Please go back to the EUDR product list and check whether your products contain any other EU relevant product.

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Based on the information provided, it is possible that your products may be subject to the EU Illegal Timber Regulation rather than the EU Deforestation Regulation.

Special rules ensure that goods are not subject to both the Illegal Timber Regulation and the EU Deforestation Regulation at the same time.

For 'timber and timber products' placed on the market until 30 December 2025, the EU Illegal Timber Regulation will apply.

For 'timber and timber products' placed on the market from 30 December 2025 until 31 December 2028, if they were produced before 29 June 2023, the EU Illegal Timber Regulation will apply. If there were produced on or after 29 June 2023, the EU Deforestation Regulation will apply.

For 'timber and timber products' placed on the market from 31 December 2028, the EU Deforestation Regulation will apply, regardless of when they were produced. As regards relevant wood-related products which do not fall within the definition of 'timber and timber products', the EU Deforestation Regulation will apply to any products produced on or after 29 June 2023, as from 30 December 2025 (or 30 June 2026 for micro or small businesses).

If you have any further questions about how the EUDR obligations will apply to your company, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

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Please go back to the EUDR product list and check whether your products contain any other EU relevant product.

Either your business activities do not concern relevant products, or they do but these were produced before the relevant cut-off date. Therefore, based on your responses, your business activities do not appear to fall within the scope of the EU Deforestation Regulation. Please go back to the EUDR product list and check whether your products contain any other EU relevant product.

If you have any further questions about how the EU Deforestation Regulation may apply to your company, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

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What is a "battery"?

A "battery" is any device delivering electrical energy generated by direct conversion of chemical energy, having internal or external storage, and consisting of one or more non-rechargeable or rechargeable battery cells, modules or of packs of them, and includes a battery that has been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing. The EUBR applies to all categories of batteries, namely portable batteries, starting, lighting and ignition batteries (SLI batteries), light means of transport batteries (LMT batteries), electric vehicle batteries and industrial batteries, regardless of their shape, volume, weight, design, material composition, chemistry, use or purpose. It also applies to batteries that are incorporated into or added to products.

What is a "manufacturer"?

A manufacturer is any natural or legal person who manufactures a battery or has a battery designed or manufactured, and markets that battery under its own name or trademark or puts it into service for its own purposes.

What is an "authorised representative"?

An authorised representative is any natural or legal person established in the EU who has received a written mandate from a manufacturer to act on its behalf in relation to the EUBR requirements.

What is an "importer"?

An importer is the natural or legal person established within the EU who places on the market a battery from a third country.

What is "placing" on the market?

'Placing a product on the market' is the first time making available a battery on the EU market.

What is "making available on the market"?

'Making available' is any supply of a battery for distribution or use on the EU market in the course of a commercial activity, whether in return for payment or free of charge.

What is a "distributor"?

A distributor is any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a battery available on the market.

What is a "fulfilment service provider"?

A fulfilment service provider is any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved, excluding postal services, parcel delivery services and any other postal services or freight transport services.

What is an "economic operator"?

An economic operator is any natural or legal person who is subject to obligations in relation to the manufacture, preparation for re-use, preparation for repurposing, repurposing or remanufacturing of batteries, the making available or the placing of batteries on the market, including online, or the putting of batteries into service in accordance with the EUBR.

What is a "producer"?

A producer is any manufacturer, importer or distributor or other natural or legal person that, irrespective of the selling technique used, including by means of distance contracts, either:

1. is established in a Member State and manufactures batteries under its own name or trademark, or has batteries designed or manufactured and supplies them for the first time under its own name or trademark, including those incorporated in appliances, light means of transport or other vehicles, within the territory of that Member State;
2. is established in a Member State and resells within the territory of that Member State, under its own name or trademark, batteries, including those incorporated in appliances, light means of transport or other vehicles, manufactured by others, on which the name or trademark of those other manufacturers does not appear;
3. is established in a Member State and supplies for the first time in that Member State on a professional basis, batteries, including those incorporated in appliances, light means of transport or other vehicles, from another Member State or from a third country; or
4. sells batteries, including those incorporated in appliances, light means of transport or other vehicles, by means of distance contracts directly to end-users, whether or not they are private households, in a Member State, and is established in another Member State or in a third country

What is a "producer"?

A producer is any manufacturer, importer or distributor or other natural or legal person that, irrespective of the selling technique used, including by means of distance contracts, either:

1. is established in a Member State and manufactures batteries under its own name or trademark, or has batteries designed or manufactured and supplies them for the first time under its own name or trademark, including those incorporated in appliances, light means of transport or other vehicles, within the territory of that Member State;
2. is established in a Member State and resells within the territory of that Member State, under its own name or trademark, batteries, including those incorporated in appliances, light means of transport or other vehicles, manufactured by others, on which the name or trademark of those other manufacturers does not appear;
3. is established in a Member State and supplies for the first time in that Member State on a professional basis, batteries, including those incorporated in appliances, light means of transport or other vehicles, from another Member State or from a third country; or
4. sells batteries, including those incorporated in appliances, light means of transport or other vehicles, by means of distance contracts directly to end-users, whether or not they are private households, in a Member State, and is established in another Member State or in a third country.

Based on your answers, your activities may fall within the scope of the Batteries Regulation and therefore may be subject to certain requirements contained therein. These requirements will vary depending on the role of your company within the supply chain.

Companies should also be aware that additional compliance obligations will take effect after the initial application of the Regulation and therefore they may become subject to additional obligations in the future. In addition, it should be noted that companies may fall under multiple classifications provided under the Regulation. This means that a company may fall under the definition of a producer as well as a manufacturer and could therefore be subject to various sets of obligations which are applied to different categories of persons under the Regulation. As a producer, you are also subject to obligations related to the management of waste batteries.

The Batteries Regulation began to apply as of 18 February 2024, gradually replacing the Batteries Directive which applied since September 2006 and is now being phased out. The provisions of the Regulation will apply in staggered fashion. Conformity assessment procedures began to apply from 18 August 2024, and rules related to the end-of-life management of batteries began to apply from 18 August 2025. Due diligence requirements have been delayed as a part of the on-going Omnibus processes in the EU so will now apply from 18 August 2027 and will only apply as of a certain turnover threshold.

If you have any questions about the obligations which apply to your company under the Batteries Regulation, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration

Based on your answers, your activities may fall within the scope of the Batteries Regulation and therefore may be subject to certain requirements contained therein. These requirements will vary depending on the role of your company within the supply chain.

Companies should also be aware that additional compliance obligations will take effect after the initial application of the Regulation and therefore they may become subject to additional obligations in the future.

The Batteries Regulation began to apply as of 18 February 2024, gradually replacing the Batteries Directive which has applied since September 2006 and which is now being phased out. The provisions of the Regulation will apply in staggered fashion. Conformity assessment procedures began to apply from 18 August 2024. Due diligence requirements have been delayed as a part of the on-going Omnibus processes in the EU so will now apply from 18 August 2027 and will only apply as of a certain turnover threshold.

If you have any questions about the obligations which apply to your company under the Batteries Regulation, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration

Based on your answers, as a producer, your activities may fall within the scope of the Batteries Regulation and therefore may be subject to certain requirements contained therein, particularly in relation to the management of waste batteries.

The Batteries Regulation began to apply as of 18 February 2024, gradually replacing the Batteries Directive which has applied since September 2006 and which is now being phased out. The provisions of the Regulation will apply in staggered fashion. The relevant rules for producers related to the end-of-life management of batteries began to apply from 18 August 2025.

If you have any questions about the obligations which apply to your company under the Batteries Regulation, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration

Based on your responses, it is likely that your activities do not fall within the scope of the Batteries Regulation. If you have any questions about the application of the Batteries Regulation to the scope of any activities undertaken by you or your company, please contact one of our regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

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'Union importer' means any natural or legal person declaring minerals or metals for release for free circulation within the meaning of Article 201 of Regulation (EU) No 952/2013 of the European Parliament and of the Council or any natural or legal person on whose behalf such declaration is made, as indicated in data elements 3/15 and 3/16 in accordance with Annex B to Commission Delegated Regulation (EU) 2015/2446.

'Release for free circulation' means, in relation to non-Union goods intended to be placed on the Union market or intended for private use or consumption within the customs territory of the Union: (a) the collection of any import duty due; (b) the collection, as appropriate, of other charges, as provided for under relevant provisions in force relating to the collection of those charges; (c) the application of commercial policy measures and prohibitions and restrictions insofar as they do not have to be applied at an earlier stage; and (d) completion of the other formalities laid down in respect of the import of the goods. Release for free circulation shall confer on non-Union goods the customs status of Union goods.

Based on your answers, your activities likely fall within the scope of the Conflict Minerals Regulation. This law regulates the trade of four minerals found to be at risk of financing armed conflict in politically unstable areas, or being mined using forced labour. These minerals are tin, tantalum, tungsten and gold, also referred to as '3TG', or 'conflict minerals'.

The EU regulation sets out different rules depending on the companies' role in the supply chain.

EU importers of 3TG must follow a five-step framework OECD 'Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas', to ensure they import these minerals and metals from responsible and conflict-free sources only, which do not contribute to conflict or illegal activities.

Upstream companies must comply with mandatory rules on due diligence when they import materials, since this stage is the riskiest part of the supply chain.

Downstream companies which import metal-stage products also must meet mandatory due diligence rules. Downstream companies which operate beyond the metal stage (e.g. sourcing finished components and distributing end-user products containing conflict minerals) do not have obligations under the regulation but are still expected to use reporting and other tools to ensure transparency in their due diligence.

If you have any further questions about how the Conflict Minerals Regulation obligations may apply to your company, please contact one of the regulatory specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

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It appears that your activities of your business fall outside of the scope of the Conflict Minerals Regulation.

If you have any questions, please contact one of the specialists at White & Case LLP.

Genevra Forwood
Partner, Brussels

Clare Connellan
Partner, London

Stephen Shergold
Partner, London

Sara Nordin
Partner, Brussels, Stockholm

This is a fast-moving area of the law, if you would like to receive our client alerts and updates please share your contact details below:

White & Case Supply Chain Subscription | Web Registration