COMPLIANCE2 min read
When a compliance date moves, your plan should not
Due-diligence obligations under the Battery Regulation have already shifted once. Here is how to build a passport programme that absorbs a moving date instead of being rescheduled by it.
By Tomas Reinholt
Dates in this regulation move. The due-diligence obligations have already been pushed once, and anyone planning against a single fixed milestone has now rescheduled their programme at least twice.
The move is a matter of record, not rumour. Regulation (EU) 2025/1561 of 18 July 2025 (OJ L, 2025/1561, 30.7.2025; CELEX 32025R1561), in force 31 July 2025, postponed the Article 48 supply-chain due-diligence obligations of Regulation (EU) 2023/1542 from 18 August 2025 to 18 August 2027, and moved the deadline for the Commission's due-diligence guidelines to 26 July 2026. Note the instrument type: this is a Regulation of the Parliament and Council under the ordinary legislative procedure, not a delegated act — a distinction worth getting right, since delegated acts cannot move the application dates of a co-decided basic act.
The passport obligation itself is the anchor everything else hangs off:
That clock is the one worth watching. Most of the surrounding obligations are either upstream of it or land alongside it.
Why a moved date rarely buys you time
A delay feels like relief and usually is not, for one reason: the long-lead work is supplier work, and supplier work does not compress.
Collecting cobalt, lithium, nickel and graphite provenance across a multi-tier supply chain means asking companies who are not your customers for data they do not currently produce. That request cycle runs in quarters. If a date moves out by a year, the honest read is that you got one more quarter of useful runway, not four.
Build the programme date-independent
The trick is to separate what you are obliged to do from when you are obliged to do it.
| Workstream | Depends on the date? | Start now? |
|---|---|---|
| Identifier scheme and data carriers | No | Yes |
| Annex XIII field mapping | No | Yes |
| Supplier evidence collection | No | Yes |
| Third-party verification of your policy | Somewhat | Scope it |
| Public disclosure of the policy | Yes | Draft it |
Three of those five are pure engineering and procurement work whose value does not change if the deadline shifts. Start them, and a date change becomes a scheduling detail rather than a replan.
The one thing worth re-checking
Keep a single source of truth for what is legally in force, cited back to the Official Journal, and re-read it when an amending act lands. A wrong date on an internal compliance plan is expensive; a wrong date in a customer-facing claim is worse.
Our compliance timeline tracks each obligation against its published source, and the FAQ covers the questions teams ask before they start.
Get the deadline off your risk register.
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