Chapter VII turns four duties into ongoing evidence work: a due-diligence policy, a traceability system, risk management, and notified-body verification with public reporting. Use this sequence to have each one operating before 18 August 2027.
01
Confirm whether Chapter VII applies to you
Start by testing scope against the net-turnover threshold rather than assuming exemption. The exemption is narrow and does not touch the other duties in the Regulation.
Run the net-turnover test against the EUR 40 million threshold, including group consolidationRemember the exemption covers only due diligence, not passports, CE conformity, or labellingConfirm which battery categories you place on the market or put into serviceNote that an authorised representative cannot take on these obligations for you
02
Adopt and communicate a due-diligence policy
The policy is the anchor the notified body and the public report both draw from. It has to reach suppliers, not just sit in a binder.
Align the policy with the OECD Due Diligence Guidance and the instruments named in Annex XCommunicate it clearly to suppliers and the publicAssign top-management oversight of the policyBuild the policy and risk-management measures into supplier contracts
03
Build the chain-of-custody and traceability system
Traceability has to identify upstream actors and origins, not stop at the immediate supplier. The evidence set is specified, so collect it in a structure a reviewer can follow.
Record trade name, supplier name and address for each materialCapture country of origin and the transaction chain from extraction to your immediate supplierRecord the quantity of each Annex X material in the battery, by percentage or weightGather notified-body verification reports covering suppliers, and CAHRA-level data such as mine of origin and trading or processing locations where those reports are unavailable
04
Assess and mitigate supply-chain risk
Identify and assess risks across the Annex X categories, then act on them with a documented plan. Mitigation is expected to reach the field, including consultation with affected stakeholders.
Assess environment, climate, and human-health risksAssess human-rights and labour-rights risks, including child labour and forced labourAssess risks to community life, including that of indigenous peoplesReport findings to top management, run a risk-management plan, and open a grievance and early-warning channel
05
Get third-party verification from a notified body
Chapter VII requires an external verification and periodic audit, not a self-declaration. The outputs of that process become part of the file you keep and disclose.
Engage a notified body to verify and periodically audit the policyObtain the verification report and approval decisionTreat internal audits or self-assessment as insufficient on their ownWatch for any industry scheme the Commission recognises as equivalent; none is recognised yet
06
Report publicly and keep the file for ten years
The Regulation ends the cycle with disclosure and retention. Both the annual report and the archived audit trail need to draw from the same current record.
Publish an annual report, including on the internet, covering the policy, significant adverse impacts and how they were addressed, and a summary of verifications naming the notified bodyMake relevant information available to immediate downstream purchasers, with regard to business confidentialityKeep the verification report, approval decision, and audit reports for ten years after the last battery under the policy was placed on the marketDisclose your conclusions when claiming Annex X materials come from recycled sources
