Due diligence evidence fields: what a passport shows about responsible sourcing

Due diligence evidence fields connect a battery passport to the supply chain due diligence duties in Chapter VII of Regulation (EU) 2023/1542. Articles 47 to 52 require economic operators above a turnover threshold, with defined exceptions, to adopt a battery due diligence policy, operate a management system, identify and assess risk, manage risk, and undergo third party verification, with reporting duties that follow. Annex X lists the raw materials and risk categories in scope, including cobalt, natural graphite, lithium and nickel, and the internationally recognised instruments that the policy must be consistent with.

The passport shows the link to that system. It does not reproduce the system. A record that tries to contain the whole due diligence file confuses a pointer with a file, and a record that contains no pointer at all leaves a reader unable to find the evidence.

Which operators fall within the due diligence duties?

The duties in Article 47 apply to economic operators that place batteries on the market, with an exemption structure based on turnover. An operator whose net turnover was below 40 million euro in the financial year preceding the last financial year, and which is not part of a group exceeding that figure on a consolidated basis, falls outside the Chapter VII duties as drafted. The threshold is a scope test, not a judgement about the operator or the battery. A passport record should not state that due diligence duties apply or do not apply without stating the basis for the position, because the basis is a turnover and group fact that the record alone cannot prove. Where the operator is outside the duties, the record should state the position in neutral terms and should not present voluntary due diligence activity as if it were a Chapter VII duty. Where the operator is inside the duties, the record points to the policy, the report and the verification, each with a date and a reference.

What does the passport show about the policy?

The passport shows, in the public tier, information on responsible sourcing and due diligence as Annex XIII point 1 requires, including a summary or reference that allows a reader to identify the due diligence policy and the report on its application. The full policy sits outside the passport, communicated to suppliers and to the public by the operator under Article 49. The record entry should identify the policy by title and date or version, the operator to whom it belongs, and the route by which the policy and the report can be accessed. A record that names a policy without a date or version cannot be checked against the policy in force at the time the battery was placed on the market. A record that links to a general sustainability page, without identifying the battery due diligence policy, fails the pointer test. The pointer must be specific enough that a reader can retrieve the exact document.

How are risk categories represented?

Annex X point 2 lists social and environmental risk categories, including human rights, labour rights, environmental harm, and risks linked to conflict affected and high risk areas. The passport does not list every risk identified in the supply chain. It shows that a risk assessment system exists, the categories it covers, and the link to the report that describes findings and risk management measures. The OECD Due Diligence Guidance for Responsible Business Conduct and the OECD Guidance for Responsible Supply Chains of Minerals, together with the UN Guiding Principles on Business and Human Rights, provide the internationally recognised framework that Article 49 and Annex X point 4 reference. The record should name the instruments the policy is consistent with, without claiming that consistency has been verified unless third party verification supports that statement. Risk representation in a record is therefore a summary of a system, with a pointer to the detail, not a risk assessment in miniature.

What role does third party verification play?

Third party verification by a notified body, under Articles 51 and 52, checks the due diligence policy, the management system and the reporting against the Regulation. Verification is not a single audit of a single battery. It is an assessment of the operator system, carried out at defined intervals, with a verification statement or report as the output. The passport record should reference the verification where one exists, with the date, the verifier type and the scope, without overstating the result. A verification statement that covers the management system does not prove that every raw material lot was traced, and a record must not present it as if it did. Conversely, the absence of a verification reference in the public view may reflect tier, timing or scope, and a reader should check the due diligence report before concluding that no verification occurred. The table below sets out the evidence chain.

How are gaps and timing shown?

Due diligence timing was changed by amendment: Regulation (EU) 2025/1561 moved the application date from 18 August 2025 to 18 August 2027, and the Commission guidance deadline was reset to 26 July 2026. A record must state the amended date with its amending source, as checked on 28 October 2026. The passport record should therefore label any other due diligence timing as expected where the act position is unsettled, and should not present a due diligence summary as a completed Chapter VII duty before the duty applies. A gap in due diligence evidence is recorded as a gap with the evidence sought, not filled by a general statement about responsible sourcing.

What must due diligence fields never claim?

Due diligence fields must never claim that a supply chain is free from risk, that a material is conflict free, or that a policy guarantees an outcome. Due diligence is a process of identifying, preventing, mitigating and accounting for risk. It does not eliminate risk by declaration. A record that claims a clean supply chain overstates the process and misleads a reader who needs to understand residual risk. This guide gives general educational information only and does not give legal advice for a particular operator, supply chain or transaction.