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EUDR, forced labour and batteries: EU rules for the Chinese supply chain

EUDR, the Forced Labour Regulation and the Batteries Regulation shift responsibility upstream: what EU customers will ask of Chinese suppliers.

· 3 min read · By the Gruppo GM China desk · Rome and Shanghai

The short answer

Three EU rules require companies to prove what happens upstream in the supply chain. The Deforestation Regulation (EUDR), applying from 30 December 2026 to large and medium-sized companies, requires geolocation of commodities such as wood, rubber and soy; the Forced Labour Regulation bans products made with forced labour from 14 December 2027, whatever their origin; the Batteries Regulation introduces the digital battery passport from February 2027 and raw-material due diligence from August 2027. European customers will pass these requirements on to their Chinese suppliers.

Who this guide is for

Chinese suppliers of furniture, paper, wood, tyres and rubber goods and soy-based products; manufacturers of batteries and battery-powered equipment; and any exporter whose European customers are subject to due diligence.

EUDR: wood, rubber and other commodities

For cattle, cocoa, coffee, oil palm, rubber, soy and wood, and for the listed derived products (furniture, paper, tyres and others), whoever places the product on the EU market must prove that it is not linked to deforestation after 31 December 2020 and that it complies with the laws of the country of production, with the coordinates of the plots of land. China is a major processor of imported wood and rubber, so traceability data going right back to the origin is needed.

The ban on products made with forced labour

The regulation applies to all products and all operators, with no size thresholds. Authorities can investigate on the basis of information received and a database of risks, and can ban, withdraw or order the disposal of goods. For suppliers, this means being able to document working conditions and the origin of components.

Batteries Regulation

Industrial, electric vehicle and light means of transport (LMT) batteries will need a digital battery passport from 18 February 2027; due diligence on cobalt, lithium, nickel and natural graphite applies from 18 August 2027; the carbon footprint follows and, from 2031, minimum recycled content. For China's battery industry this is the most significant change on the European market.

Step by step

  1. 01Map the products sold in the EU that fall under the three regulations
  2. 02Trace the supply chain back to the raw materials, with suppliers and countries of origin
  3. 03Collect geolocation data and proof of legality for EUDR commodities
  4. 04Adopt a due diligence policy and supplier audits
  5. 05Prepare the data for the battery passport and the carbon footprint
  6. 06Agree data formats and delivery times with European customers

Mistakes to avoid

  • Assuming a generic sustainability certificate is enough
  • Stopping at the direct supplier without tracing back to the raw materials
  • Waiting for the customer's formal request before starting

How we help

From Shanghai we work with your suppliers to trace the supply chain and collect data and documents; from Rome we turn them into the format European customers and authorities require.

Related regulations and deadlines

Chinese supply chain and EU rules

The obligations fall on whoever places the product on the EU market, but without the Chinese supplier's data the importer cannot complete the due diligence statement. In practice, the request reaches the whole supply chain.

From 14 December 2027, for all products placed on or exported from the EU market, including online sales.

A digital record, accessible via a QR code, with information on composition, performance, origin of materials and carbon footprint. It is mandatory from 18 February 2027 for industrial batteries above 2 kWh, electric vehicle batteries and batteries for light means of transport.

No. The Forced Labour Regulation has no thresholds; the EUDR only gives micro and small companies placing products on the EU market more time.

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