The new EU Battery Regulation (2023/1542) replaced the 2006 directive, creating a unified legal framework across all 28 member states. It applies to all battery types sold in the EU, including those integrated into electronics, with key provisions taking effect from August 18, 2024. The regulation introduces a wide range of obligations covering the entire battery lifecycle, from sourcing materials to end-of-life recycling. This shift means producers now hold far greater responsibility for their products’ environmental impact. For instance, by 2027, portable batteries in appliances must be readily removable and replaceable by the end-user, a major change for many product designs. These new rules require a proactive approach to compliance management.

In Germany, the EU regulation is implemented through the national Battery Act (BattG). This law mandates that any company placing batteries on the German market must register with the national register, Stiftung EAR. The term “manufacturer” under BattG is broad, including importers and online retailers selling directly to German consumers. This registration, which provides a unique Batt-Reg.-Nr. DE, is a legal prerequisite for market access. More than 60% of manufacturers can find synergies between battery and WEEE registration processes. You can learn more about how to register with a take-back scheme to fulfill your obligations. This national framework adds another layer of specific requirements for businesses.

The transition to the new battery regulation is phased, but several critical deadlines have already passed or are imminent. Since August 18, 2024, all batteries require a CE marking to certify compliance with EU standards. By February 18, 2027, portable batteries must be designed for easy removal and replacement by consumers. Furthermore, from August 18, 2025, producers outside Germany must appoint a local authorized representative to manage their EPR duties. These are not suggestions; they are mandatory dates for market participation. Missing these deadlines directly translates to market exclusion and financial penalties. The phased rollout requires careful planning and immediate action.

Navigating the battery registration for products with integrated batteries can be managed with a clear, 4-step process. Following these steps ensures you meet all legal requirements under the BattG and EU Regulation.

1. Register with Stiftung EAR: Every producer must register with Germany’s official directory, Stiftung EAR, to receive a Batt-Reg.-Nr. DE number, which is essential for legal sales.
2. Appoint an Authorized Representative: Non-German producers must appoint a Germany-based authorized representative by August 18, 2025, to handle all compliance tasks.
3. Join a Producer Responsibility Organization (PRO): You must contract with an approved take-back scheme to manage the collection and recycling of your used batteries, fulfilling your take-back obligations.
4. Fulfill Reporting Duties: Producers are required to submit regular reports detailing the volume and types of batteries placed on the market, ensuring continuous transparency.

This structured approach is the foundation of your compliance strategy.

The new regulation introduces stringent due diligence obligations to promote ethical sourcing of raw materials like lithium and cobalt. Companies must establish policies to identify and mitigate social and environmental risks within their supply chains. Additionally, new labeling rules provide consumers with clear information. By August 2026, batteries must feature a QR code linking to a digital battery passport. This passport will contain detailed information, including material composition and carbon footprint data. You can find more details on how to label batteries correctly. These transparency measures are designed to create a more sustainable and accountable battery market.

Ignoring the BattG and EU Battery Regulation carries severe consequences that extend beyond financial loss. German authorities can issue fines of up to €100,000 for each violation, such as failing to register or incorrect labeling. Beyond fines, non-compliant companies face immediate sales bans, effectively halting all business activities in the German market. Marketplaces like Amazon are now legally required to verify the EPR registration of their sellers. This means a missing Batt-Reg.-Nr. DE will get your products delisted almost immediately. The reputational damage from being labeled as a non-compliant entity can have long-lasting effects on customer trust. These risks make proactive compliance an essential business function.

The complexity of these regulations demands expert guidance to ensure 100% legal conformity. Deutsche Recycling offers a full-service solution to manage all your obligations for battery registration for products with integrated batteries. Our team of experts handles the entire process, allowing you to focus on your core business without the administrative burden. We ensure you can handle reporting in one place efficiently.

• Complete Registration Management: We handle your registration with Stiftung EAR and act as your authorized representative.
• Nationwide Take-Back System: Our certified take-back scheme ensures you meet all collection and recycling targets across Germany.
• Accurate and Timely Reporting: We manage all your reporting duties to the authorities, guaranteeing accuracy and preventing penalties.
• Expert Consultation: Our team provides continuous support, keeping you updated on regulatory changes and ensuring ongoing compliance.

Take action now to secure your business. Contact Deutsche Recycling today to ensure you comply with all regulations quickly and efficiently. Our experts are ready to provide an individual consultation and get your compliance process started immediately.