EU Battery Regulation – Summary of Omnibus IV Proposal Impacts
By Glassdome
Overview
On May 17, 2025, the European Commission adopted Omnibus IV, a regulatory simplification package introduced under its broader “Red Tape Cutting” initiative. The initiative aims to reduce administrative burdens on SMEs and small mid-caps by postponing certain requirements and expanding exemptions across existing EU regulations.
Omnibus IV directly affects the EU Battery Regulation, including notable changes to due diligence timelines and disclosure exemption thresholds. However, obligations related to carbon footprint (CF) declarations remain unchanged.
📎 [Official press release – Omnibus IV]
📎 Simplification Package Overview
📎 Proposal for Small Mid-Caps (PDF)
📎 Proposal on Due Diligence Postponement (PDF)
Key Impacts on the EU Battery Regulation
1. Postponement of Supply Chain Due Diligence Requirements
- Original enforcement date: August 18, 2025
- Proposed new enforcement date: August 18, 2027
This two-year postponement reflects limited availability of Notified Bodies and the need to align with the upcoming Corporate Sustainability Due Diligence Directive (CSDDD).
2. Expansion of Disclosure Exemption Criteria (Article 47)
- Current threshold: Companies with annual turnover below €4 million
- Proposed threshold:
- Up to 750 employees, and
- Annual turnover of up to €150 million or total assets of up to €129 million
This expansion could exempt a significantly larger number of companies from certain disclosure obligations under the EU Battery Regulation.
3. No Change to Carbon Footprint (PCF) Requirements
Requirements under Article 7 related to product carbon footprint declarations are not affected by the Omnibus IV proposal. These obligations remain in force and will take effect 18 months after the relevant Delegated Act is adopted.
Companies are advised to continue preparing for CF compliance as planned.
Next Steps in the Legislative Process
- European Commission submission – Completed
- Review and amendments by the European Parliament
- Position adoption by the Council of the EU
- (If required) Conciliation process between Parliament and Council
- Final adoption and publication in the Official Journal of the EU
The Omnibus IV proposals are expected to be finalized by late 2025.
Implications for Carbon Footprint Compliance
While Omnibus IV introduces flexibility in certain regulatory areas, carbon footprint obligations remain a central pillar of EU sustainability policy. Product Carbon Footprint (PCF) requirements—unlike broader Corporate Carbon Footprint (CCF) topics—continue to be prioritized across major EU frameworks such as the Battery Regulation and the Ecodesign for Sustainable Products Regulation (ESPR).
These developments should be viewed not as a rollback of sustainability commitments, but as a response to operational readiness challenges. The core direction of EU policy—toward greater transparency, accountability, and climate responsibility—remains firmly in place.
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