Articles 47–53 of Regulation (EU) 2023/1542 and Annex X impose battery-specific supply-chain due diligence for cobalt, lithium, nickel and natural graphite, applicable since 18 August 2025 to every battery category. Because nickel-metal hydride (NiMH) cells contain nickel and hydrogen-storage alloys with rare-earth content, this regime applies directly to NiMH makers. This paper builds the management system European buyers expect to see.
Every economic operator placing batteries on the EU market must establish, disclose and maintain a supply-chain due-diligence policy covering the listed raw materials, identify and assess environmental, climate, human-rights, labour and community (including indigenous-population) risks, implement risk-mitigation plans, verify the policy through an independent third party (a notified body or accredited conformity-assessment body), and report publicly. The structure follows the OECD Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas and the UN Guiding Principles on Business and Human Rights; SMEs may use lighter procedures but cannot opt out.
Annex X operationalises five steps: (1) management systems — map suppliers down to mine or refinery level, collect country of origin, chain-of-custody and ownership information, and assign internal controls and staff training; (2) risk identification and assessment in the supply chain against environmental, climate, human-rights, labour and community risk categories; (3) a risk-response strategy with measurable mitigation actions, supplier engagement and, where risks cannot be mitigated, suspension or disengagement; (4) third-party verification by an independent body at least every two years and after material changes; and (5) annual public disclosure of the policy, findings and remediation, accessible through the 2027 QR link. The flow above animates this chain — a policy without verification and disclosure is non-compliant.
For a NiMH manufacturer the work concentrates on three input streams. Nickel: map from cathode foam/plate through nickel sulfate or metal refineries to mine; collect certificates of origin, chain-of-custody and any smelter/refiner conformance to recognised responsible-mining standards; document recycled nickel from battery and stainless scrap as a risk-reducing stream. Rare-earth elements in the hydrogen-storage (AB5/AB2) alloy: although not one of the four listed materials, they sit inside the nickel-alloy supply chain and buyers increasingly ask for them under the community-risk category. Natural graphite and cobalt: absent or minimal in NiMH — a documented negative declaration closes the question. The layered diagram below maps materials to risk categories.
Verification is not an internal audit: Annex X requires an independent notified or accredited body to verify that the policy conforms to the Regulation and that it is actually implemented — supplier interviews, document sampling and traceability tests. The public report must be published on the company website, kept available for at least five years and reachable via the battery QR from 2027. Buyers routinely request the report, the verification certificate and a sample supplier-risk assessment as part of vendor onboarding; absence is treated as a hard stop under their own Article 47 obligations because the importer inherits responsibility for its upstream chain.
Audit findings cluster around four gaps: supplier maps that stop at the alloy vendor rather than the refinery; policies that name categories but contain no risk register with severity ratings; mitigation plans without deadlines and owners; and verification performed by a related laboratory rather than an independent accredited body. Closing them requires a living due-diligence dossier: supplier master list with origin data, risk register refreshed per supplier change, engagement records, the two-year verification cycle, and an annual disclosure aligned in date with the sustainability report.
Weijiang Power maintains an Annex X due-diligence system for its NiMH range: refinery-level nickel supply mapping with chain-of-custody certificates, documented recycled-nickel streams, a rated environmental and human-rights risk register, independent third-party verification and a public due-diligence policy linked from product documentation. Request our policy, verification certificate and supplier-risk summary for your vendor file and we deliver them in the format your compliance team uses.
