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Battery Materials & Sourcing Compliance

Sourcing compliance for batteries rests on supplier controls: multi-tier mapping, material declarations, origin evidence for high-risk inputs, and change notification. Without them, restricted substance, due diligence, passport and recycled-content obligations further down the lifecycle cannot be evidenced.

Which materials carry obligations (restricted substances, substances of very high concern, conflict-affected minerals, critical raw materials) is mapped on Regulated Battery Materials & Substances.

Responsible sourcing for cobalt and other high-risk materials

Cobalt and similar inputs are legal to use; sourcing geography and human rights risk make them subject to supply chain due diligence. Audits fail when these materials are handled only as technical commodities.

Keep legal restricted substance controls separate from responsible sourcing controls.
Maintain a high-risk material register used for due diligence.
Map cobalt-bearing inputs to supplier tiers and country-of-origin evidence where possible.

Minimum traceability controls

Control	What to do	Output
Supplier tier mapping	Identify at least Tier 1 and Tier 2 sources for critical materials and key subassemblies	Multi-tier map and gap register
Material declarations	Collect standardized declarations for restricted substances and chemical composition where required	Declaration set tied to part numbers and revisions
Country-of-origin evidence	Capture origin evidence for high-risk materials when customers or programs require it	Origin evidence package and supplier attestations
Change control triggers	Define which supplier changes require re-evaluation of compliance evidence	Trigger list and re-validation workflow
Retention	Centralize evidence under a record retention policy	Evidence repository and retention schedule

Documents to request from suppliers

Document	What it is	Why it matters
Material declaration	Structured disclosure of regulated substances and relevant chemistry	Supports Restriction of Hazardous Substances (RoHS) and EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation compliance and downstream reporting
Safety data sheets (SDS)	Hazard information for relevant materials and mixtures	Aligns transport, storage and handling controls with the hazard profile
Responsible sourcing attestation	Supplier due diligence statement for high-risk materials	Answers customer audits and sourcing inquiries
Test reports where applicable	Lab evidence against specific restricted substance limits	Backs up paper declarations
Change notification commitment	Supplier agreement to notify material, process or sub-tier changes	Prevents unreviewed changes from invalidating evidence

Supplier roles, evidence packages, traceability data fields and audits are covered in more depth on Battery Supplier Compliance & Traceability.

Links to other compliance areas

Digital Battery Passport Basics: material provenance and traceability data where passports apply.
Battery Recycled Content & Recovery Claims: recycled-content claims depend on upstream custody records.
Battery Risk Management: supply chain risk tracked in the compliance risk register.

Related Coverage

Disclaimer. Informational guidance only. Not legal advice. Material and sourcing obligations vary by jurisdiction, customer requirements, and program participation. Use this page to structure your controls and evidence, then validate requirements for your markets and battery categories.