Nickel and graphite chain evidence follows nickel from mine to refiner to cathode precursor, and natural graphite from mine to processor to anode production, for a specified battery model. Nickel evidence must distinguish battery grade nickel from other nickel grades, because grade decides whether the material is relevant to the battery record. Graphite evidence must distinguish natural graphite from synthetic graphite, because Chapter VII names natural graphite as the covered material. The record must show origin, operator, site, material form, grade where relevant, quantity, and period at each stage. A record that names only a trader gives no answer about the mine or the processor.
Nickel chain evidence means records for nickel bearing material from extraction through refining to battery use. Natural graphite chain evidence means records for natural graphite from extraction through purification and shaping to anode use. The scope is the quantity in the battery model stated, for the period stated.
What is the legal frame for this record?
Nickel and natural graphite chain evidence sits inside that sequence, so a record that shows only one step leaves the chain of reasoning incomplete. An anode producer sourcing natural graphite flake through a processor therefore needs a file that shows the policy, the owner of the policy, the date of adoption, and the review cycle. A graphite shipment should state the mine, the flake size and purity after processing, the processor, and the anode producer, so the quantity can be reconciled with anode output for the period.
How is the chain mapped?
The map should name each tier that handles nickel and natural graphite chain evidence, record the function of each actor, and note where material changes form, such as refining, precursor production, cathode production, cell production, and pack assembly. Mine origin records, processor certificates, and grade statements should be tied to a named tier, a named site where that information is known, and a date. An anode producer sourcing natural graphite flake through a processor should record gaps on the map itself, with the reason for each gap and the next step planned. Laterite and sulphide nickel ores follow different processing routes, and the record should state the ore type and the refining route, since the route affects the sites and the environmental risks that need assessment.
How is evidence judged?
A supplier statement, a contract clause, a third party audit summary, a mass balance record, and a chain of custody document do not carry equal weight, and the record should say which type supports each claim about nickel and natural graphite chain evidence. Mine origin records, processor certificates, and grade statements needs a source name, a collection date, a coverage period, and a statement of what was actually checked. An anode producer sourcing natural graphite flake through a processor should separate facts received from conclusions drawn, so a later reviewer can test the conclusion. A graphite shipment should state the mine, the flake size and purity after processing, the processor, and the anode producer, so the quantity can be reconciled with anode output for the period.
How is risk identified and assessed?
A red flag can be a place of origin, a processing route, a supplier practice, a change of ownership, or a gap in records for nickel and natural graphite chain evidence. Laterite and sulphide nickel ores follow different processing routes, and the record should state the ore type and the refining route, since the route affects the sites and the environmental risks that need assessment. An anode producer sourcing natural graphite flake through a processor should date each assessment and name the person or function responsible for the next review.
How is mitigation planned and followed up?
For nickel and natural graphite chain evidence, the plan should state the risk addressed, the action chosen, the supplier or site involved, the support offered, and the evidence that will show whether the action worked. Mine origin records, processor certificates, and grade statements collected after the action should be compared with the position before the action, using the same measure where possible. A graphite shipment should state the mine, the flake size and purity after processing, the processor, and the anode producer, so the quantity can be reconciled with anode output for the period.
How is reporting checked?
The due diligence report should summarise the policy, the management system, the risks found, the actions taken, and the verification arranged for nickel and natural graphite chain evidence, without disclosing confidential commercial detail that the Regulation does not require to be published. An anode producer sourcing natural graphite flake through a processor should check that every public claim can be traced to an internal record, and that the report date, coverage period, and scope match the internal file. Laterite and sulphide nickel ores follow different processing routes, and the record should state the ore type and the refining route, since the route affects the sites and the environmental risks that need assessment.
How is battery grade nickel separated from other nickel in the file?
Separation starts at the refiner record, which states the grade, the output form, and the quantity of battery grade material, distinct from other grades produced at the same site. The cathode precursor record then states the battery grade quantity received, the quantity used, and the stock held, for the same period. A worked check takes one precursor batch, traces the nickel quantity back to the refiner grade statement, and forward to the cell production record, checking that the grade statement follows the quantity at each step. Natural graphite is separated in the same way, by a processor statement of natural origin, purity, and shaping, distinct from synthetic graphite quantities held at the same site.
| Material | Origin record | Processing record |
|---|---|---|
| Nickel | Mine, ore type, operator | Refiner, grade, output form |
| Natural graphite | Mine, operator, flake source | Processor, purity, shaping method |
| Synthetic graphite | Not a covered material under Chapter VII | Record the distinction, do not mix quantities |
Grade and form are part of the evidence, and a quantity without grade or form cannot be matched to the battery that the record claims to describe.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, EUR-Lex ↗
- OECD Due Diligence Guidance, full text PDF ↗
- Regulation (EU) 2023/1542, EUR-Lex summary ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.