The Compliance Pathway for Miners and Traders Under the EUBR

Because Europe’s new Battery Regulation has global reach, extending obligations far beyond the factories and showrooms of the EU. If your materials could end up in batteries sold in Europe, you are part of the regulation’s story — whether you realize it or not. 

A Regulation That Starts at the Mine 

The EU Battery Regulation (EUBR), in force since August 2023, is the first legislation in the world to govern the entire battery lifecycle — from mining and refining, through manufacturing, to recycling. It is ambitious: Europe wants to secure sustainable, ethical, and circular batteries as it electrifies transport and industry. 

What does that mean for miners and traders? For the first time, obligations usually reserved for manufacturers now flow upstream to raw material producers and intermediaries. At the core of these obligations lie three principles: conduct due diligence, ensure traceability, and provide data for the upcoming battery passport. 

In practice, this means a cobalt exporter in the DRC or a nickel trader in Indonesia will need to prove not just the quality of their product, but also its ethical and environmental footprint. 

The Road to 2027 

The regulation is being phased in. Today, companies are busy mapping supply chains and building systems to estimate carbon footprint. The first due diligence checks will apply from 2027. By 2026, battery passports will be tested, and from 2027 every industrial, EV, and light transport battery placed on the EU market must be accompanied by a digital record containing origin, sustainability, and chain-of-custody information. 

This timeline matters. It gives miners and traders a narrow window to prepare. Waiting until 2027 is not an option — customers will begin demanding compliant data much earlier, as their own reporting deadlines approach. 

From Compliance Burden to Market Opportunity 

For many upstream companies, the instinctive reaction is concern: new audits, new reporting, new scrutiny. But there is another way to view it. By aligning with the EUBR, miners and traders can position themselves as preferred suppliers to Europe’s battery industry, which is forecast to be worth more than €250 billion by 2030. 

Consider a lithium trader supplying European cathode producers. By establishing traceability systems, publishing risk assessments, and sharing carbon footprint data, this trader doesn’t just tick a regulatory box — it gains credibility and secures long-term contracts. Compliance, in other words, becomes a competitive edge. 

Preparing for the Battery Passport Era 

The digital battery passport is at the heart of the regulation. For traders and miners, it means that the material you ship in bulk today will tomorrow be broken down into data fields — origin, emissions, water use, social safeguards — visible to customers and, in some cases, to consumers. 

This transparency will transform commercial relationships. Buyers will increasingly ask not “what’s your price?” but “can I integrate your data into my passport system?” Those who cannot answer risk being sidelined. Those who can will find themselves at the front of the line. 

The Path Ahead 

The EU Battery Regulation is not just another layer of compliance paperwork. It is a gatekeeper to market access. For miners and traders, the challenge is real — but so is the opportunity. By embracing due diligence, traceability, and transparency today, upstream actors can ensure they remain essential to Europe’s decarbonization journey tomorrow. 

The pathway is already visible: start early, build trust with customers, and treat compliance not as a burden but as the new language of trade. By the time the first passports become mandatory in 2027, those who have prepared will not be scrambling; they will be leading.