Since 2009, the Battery Act (BattG) has regulated the disposal of waste batteries and rechargeable batteries in Germany. This era has come to an end: on October 7, 2025, the Battery Law Implementation Act (BattDG) entered into force, replacing the old BattG. It was officially promulgated as part of the EU Battery Law Adaptation Act on October 6, 2025.

Since then, a comprehensive national legal framework has been in place in Germany, complementing the directly applicable EU Battery Regulation (EU) 2023/1542. This article clarifies the innovations and updates introduced by this legislation.

The EU Battery Regulation at a Glance

With the Battery Regulation, the EU has taken a decisive step toward more economical handling of rechargeable and electronic devices.

Effective date: The BattDG has been in force since October 7, 2025, completely replacing the Battery Act (BattG) of 2009.
EU framework: The EU Battery Regulation (EU) 2023/1542 applies directly in all member states; the old EU Battery Directive 2006/66/EC expired on August 18, 2025.
Producer responsibility: Since January 1, 2026, manufacturers must participate in an approved Producer Responsibility Organization (PRO) for each battery category.
Take-back obligations: Since then, distributors must take back waste batteries free of charge for all categories they carry or have carried in their product range, regardless of whether a new purchase is made.
Future milestones: The digital battery passport and the mandatory replaceability of portable batteries will apply as of February 18, 2027.

What are the objectives of the Battery Regulation and the Battery Act?

Regulation (EU) 2023/1542 entered into force in August 2023 and became partially applicable on August 18, 2024. Consequently, the EU Battery Directive 2006/66/EC was definitively repealed in August 2025. The fundamental difference from the old EU Battery Directive is that a directive required each country to transpose it into national law—resulting in varying national rules. In contrast, a regulation is directly applicable. For companies with EU-wide distribution, this ensures greater uniformity regarding product requirements, though national variations remain for registration and take-back systems.

Accordingly, the Battery Regulation pursues ambitious goals in Germany. Foremost among these are increased recycling, higher collection rates, enhanced product responsibility, and more sustainable manufacturing. This framework is designed to strengthen environmental compliance across the EU.

How is Germany implementing the regulation through the Battery Act?

The previous Battery Act (BattG) did not account for the new EU regulation. Consequently, a new national law became necessary. Following the draft bill of May 27, 2025, and a public hearing in the Bundestag’s Environmental Committee on September 1, 2025, the legislative process was swiftly concluded.

The EU Battery Law Adaptation Act was promulgated in 2025 and substantially entered into force on October 7, 2025. The centerpiece of this legislation is the Battery Law Implementation Act (BattDG), which completely replaces the previous Battery Act.

As a result, a dual legal framework has been in place in Germany since October 2025: the EU regulation governs product requirements, while the BattDG regulates national enforcement via the stiftung ear, which has once again been entrusted with public authority tasks by the Federal Environment Agency (UBA).

How does the Battery Act operate in practice?

In recent years, the EU has increasingly focused on the ecological disposal of electronic waste. Specifically, measures have extended beyond simply improving disposal infrastructure. Initiatives like the Repairability Score and the Ecodesign Directive/Regulation aim to proactively prevent unnecessary waste and assist consumers in making informed decisions.

This development also impacts the Battery Regulation and the applicable Battery Act. Below, we highlight the key factors to consider now.

New battery categories

To simplify battery disposal, the law establishes clear classifications into five distinct categories.

These categories are structured as follows:

Portable batteries
LMT batteries (Light Means of Transport – e.g., e-scooters, e-bikes)
SLI batteries (Starting, lighting, and ignition)
Electric vehicle batteries
Industrial batteries

Correct classification is not a mere formality. It determines registration obligations, compliance fees, and take-back pathways. Reporting an industrial battery as a portable battery risks incorrect financial contributions and can ultimately invalidate the registration.

Extended take-back obligations – who must accept which batteries?

The take-back obligation is a central pillar of the Battery Act, involving all stakeholders throughout a battery’s life cycle.

Distributors must take back waste batteries of all categories free of charge if they offer or have offered corresponding new batteries in their portfolio (§ 14 BattDG)—regardless of brand, origin, design, or whether a new battery is purchased.
Public waste management authorities have also been accepting waste LMT batteries from private households (such as e-bike and e-scooter batteries) since January 1, 2026.
Manufacturers fulfill their take-back obligations through an approved PRO; the previous obligation to operate an individual take-back system has been abolished.
PROs must collect waste batteries from collection points within 15 days, applicable to waste portable batteries from a collection volume of 90 kilograms (§ 11 BattDG)
End-users are legally required to dispose of waste batteries separately from household waste (§ 6 BattDG).

What are the collection targets under the Battery Act?

The Battery Disposal Act operates on target quotas. Germany is initially maintaining its existing target via § 13 BattDG before aligning with the broader EU objectives:

Waste portable batteries: 50 percent until December 31, 2026
Waste portable batteries: 63 percent by the end of 2027, 73 percent by the end of 2030
Waste LMT batteries: 51 percent by the end of 2028, 61 percent by the end of 2031

Registration, PRO participation, and deadlines under the Battery Act

Instead of a registration presumption, a strict registration mandate with a transitional deadline has applied since the transition. Existing registrations under the old Battery Act had to be converted to the five new categories and assigned to an approved PRO by mid-January 2026.

Market ban: Placing products on the market is prohibited without a valid registration with stiftung ear.
Mandatory disclosures: Required information includes the chemical composition and the manufacturer’s tax ID.
Authorized representatives: Companies established outside of Germany require an authorized representative based in Germany.
Deemed manufacturers: Anyone importing devices with built-in rechargeable batteries is legally considered a manufacturer – even in cases of pure resale.
Data maintenance: Master data must be kept up to date; obsolete information can result in the revocation of distribution rights.

However, these points do not mark the end of the updates surrounding the Battery Act. Further measures are scheduled for the coming years, such as including a QR code with detailed information on packaging materials or the digital battery passport for electric vehicle, LMT, and industrial batteries exceeding 2 kWh. Consequently, batteries will follow the precedent set by the digital product passport for textiles.

What does the Battery Act mean for manufacturers and distributors?

The new Battery Act presents distributors and manufacturers primarily with bureaucratic challenges. All relevant data must be collected, processed, and made available to the competent authorities. Concurrently, due diligence requirements, along with fine and liability risks, represent further factors that must be closely monitored.

The heightened verification obligations of online marketplaces also play a central role, as distributors and manufacturers without registrations and proof of compliance can be issued cease-and-desist letters and have their product listings removed.

Specifically, the Battery Act entails the following:

Market exclusion: Anyone placing batteries or rechargeable batteries on the market for the first time must be registered, assigned to a PRO, and correctly categorized – otherwise, they face a market ban.
E-commerce and imports: Online retailers and foreign importers must also comply with these specifications, as EU law applies directly.
Product data compliance: Product data becomes a compliance task; capacity, chemical composition, and disposal instructions must be structured within the article data rather than entered into free-text fields.
Contractual safeguards: Anyone sourcing finished devices with integrated rechargeable batteries should secure contractual guarantees that the enclosed batteries have been properly reported.

What lies ahead for the Battery Act?

The reform of battery law is complete, but its implementation is ongoing. While the framework is established by the BattDG and the EU Battery Regulation, the challenging deadlines fall within the years 2027 and 2028.

We recommend that companies review their registrations, categories, and product data immediately, and not postpone preparations for the battery passport and replaceability requirements until the final quarter. At the political level, a deposit system for lithium-ion batteries continues to be debated – a topic that is highly likely to return in the medium term. For questions or support, Deutsche Recycling GmbH is available to assist.

FAQ: Battery Act

What registration obligations apply to manufacturers under the Battery Act?

Anyone qualifying as a manufacturer under the Battery Act strictly requires a corresponding registration with stiftung ear. Additionally, since the beginning of 2026, participation in an approved Producer Responsibility Organization (PRO) is required for each respective battery category. Companies should treat registration as a prerequisite for distribution and ensure it is completed prior to launch.

What does the Battery Act mean for importers and online retailers?

The Battery Act does not exclusively affect traditional battery manufacturers. Companies that import batteries or products with built-in rechargeable batteries and make them available on the German market for the first time can also assume manufacturer obligations. Online retailers, in particular, should clarify who is responsible for registration, reporting, and other compliance requirements before commencing sales.

What is the difference between the EU Battery Directive and the new EU Battery Regulation?

Under the previous Battery Directive, member states had to transpose European specifications into their respective national laws first. The EU Battery Regulation operates differently, as it applies directly across all member states. This harmonizes many requirements across Europe, even though national specificities remain regarding registration, regulatory jurisdictions, and take-back structures.

What objectives does the Battery Regulation pursue in Germany?

The Battery Regulation in Germany aims to make batteries more sustainable throughout their entire life cycle—from manufacturing to recycling. To achieve this, it introduces higher collection targets, enhanced producer responsibility, and additional product and information requirements. In the long term, this is intended to keep more raw materials in the circular economy and reduce problematic battery waste.

What is the digital battery passport under the Battery Act and EU Battery Regulation?

The digital battery passport is designed to make critical information about a battery digitally accessible throughout its life cycle. It is mandatory for electric vehicle batteries, LMT batteries, and certain industrial batteries with a capacity exceeding 2 kWh. Starting in February 2027, it will become an essential component of Battery Act and EU compliance for numerous companies.