Supply chain mapping

Supply chain mapping is the dated record of every tier that handles a covered raw material from extraction to the finished battery, with the function of each actor and the point at which the material changes form. A list of direct suppliers is not a map, because risk in battery supply chains often sits two or more tiers upstream from the battery manufacturer. The map must show mines, traders, refiners, precursor and cathode producers, cell producers, and pack assemblers where those stages are known, and must mark each unknown stage as a gap. Without that structure, risk assessment has no place to attach.

A supply chain map is a structured record of actors, places, functions, and material flows for a specified battery model or material. The scope is the chain for cobalt, lithium, nickel, and natural graphite in the batteries covered by Chapter VII, for the period stated on the map.

What is the legal frame for this record?

Supply chain mapping for covered raw materials sits inside that sequence, so a record that shows only one step leaves the chain of reasoning incomplete. A pack assembler sourcing cells from two cell producers therefore needs a file that shows the policy, the owner of the policy, the date of adoption, and the review cycle. A cell producer that buys cathode material from a trader must record the trader, the cathode producer, and the refiner behind the cathode producer, or record why the refiner is not yet known.

How is the chain mapped?

The map should name each tier that handles supply chain mapping for covered raw materials, record the function of each actor, and note where material changes form, such as refining, precursor production, cathode production, cell production, and pack assembly. The tier map, site records, and material flow notes should be tied to a named tier, a named site where that information is known, and a date. A pack assembler sourcing cells from two cell producers should record gaps on the map itself, with the reason for each gap and the next step planned. Mass balance and book and claim methods must not be confused on the map, because each method makes a different claim about the link between a quantity of material and a quantity of battery output.

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 supply chain mapping for covered raw materials. The tier map, site records, and material flow notes needs a source name, a collection date, a coverage period, and a statement of what was actually checked. A pack assembler sourcing cells from two cell producers should separate facts received from conclusions drawn, so a later reviewer can test the conclusion. A cell producer that buys cathode material from a trader must record the trader, the cathode producer, and the refiner behind the cathode producer, or record why the refiner is not yet known.

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 supply chain mapping for covered raw materials. Mass balance and book and claim methods must not be confused on the map, because each method makes a different claim about the link between a quantity of material and a quantity of battery output. A pack assembler sourcing cells from two cell producers should date each assessment and name the person or function responsible for the next review.

How is mitigation planned and followed up?

For supply chain mapping for covered raw materials, 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. The tier map, site records, and material flow notes collected after the action should be compared with the position before the action, using the same measure where possible. A cell producer that buys cathode material from a trader must record the trader, the cathode producer, and the refiner behind the cathode producer, or record why the refiner is not yet known.

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 supply chain mapping for covered raw materials, without disclosing confidential commercial detail that the Regulation does not require to be published. A pack assembler sourcing cells from two cell producers 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. Mass balance and book and claim methods must not be confused on the map, because each method makes a different claim about the link between a quantity of material and a quantity of battery output.

How is a map tested against a real shipment?

A map is tested by taking one real shipment and walking it backwards through the map, tier by tier. Start with the finished battery identifier, find the pack assembler, then the cell producer, then the cathode or anode producer, then the refiner or processor, then the trader, then the mine or brine operation. At each step, check that the map names the actor, the site, the material form, and the quantity, and that the dates align. A shipment of lithium carbonate that arrives with a processor name but no brine source fails the test at the first upstream step. The test should be repeated for one shipment of each covered material each year, and the results filed with the map version that was tested.

A map stays useful only while it is updated, and a map that has not been reviewed after a supplier change describes a chain that no longer exists.