The legal framework for batteries in Germany is defined by two key pieces of legislation: the German Battery Act (BattG) and the new, overarching EU Battery Regulation 2023/1542. The EU regulation introduces significant new rules that will be enforced in phases, with some requirements already active since February 2024. Companies placing batteries on the market for the first time must take immediate action to align with these evolving standards. Waiting to adapt could expose your business to severe penalties, including sales prohibitions across the entire EU market of over 450 million consumers.

Under these regulations, every manufacturer, importer, and distributor has Extended Producer Responsibility (EPR), covering the product’s entire lifecycle. This responsibility is not just about recycling; it begins with proper registration and labeling before a single battery is sold. The transition period is over, and enforcement is tightening. For more on EPR, get a compliance provider to ensure you are covered. If you have not yet addressed these obligations, contacting Deutsche Recycling is an urgent first step to secure your market access.

Every battery sold in Germany must display specific symbols to inform consumers about correct disposal. The most critical of these is the crossed-out wheeled bin, indicating that the battery must not be discarded in household waste. This symbol must cover at least 3% of the battery’s largest side, with a maximum size of 5×5 cm, ensuring it is clearly visible to the end-user. For cylindrical cells, the symbol must cover at least 1.5% of the surface area.

Additionally, if a battery contains certain heavy metals above specified limits, it must be labeled with the corresponding chemical symbol. The thresholds are:

• Pb: for batteries containing more than 0.004% lead.
• Cd: for batteries with more than 0.002% cadmium.
• Hg: for batteries containing more than 0.0005% mercury.

These symbols must be printed beneath the crossed-out bin symbol and must meet specific size requirements to be compliant. These foundational markings are a non-negotiable part of how to label products correctly. Understanding these basic requirements is the first step toward broader compliance.

As of August 18, 2024, all batteries placed on the EU market must bear the CE marking. This mark signifies that the product has been assessed by the manufacturer and deemed to meet EU safety, health, and environmental protection requirements. It is a mandatory declaration of conformity and a prerequisite for market access. The addition of the CE mark is a key change introduced by the EU Battery Regulation 2023/1542, impacting every single battery type.

Failure to affix the CE mark can result in products being held at customs or withdrawn from the market. This single symbol is your passport to the EU’s 27 member states. For businesses that have not yet updated their labeling processes, this presents an immediate compliance gap. You must ensure your entire battery portfolio, including products with integrated batteries, meets this rule. This change underscores the need for a proactive compliance strategy.

The new EU Battery Regulation is phasing in even more extensive labeling rules that will revolutionize transparency by 2026 and 2027. Batteries will require labels detailing capacity, performance, durability, and chemical composition. A QR code will also become mandatory, linking to a Digital Battery Passport that provides detailed information on the battery’s entire lifecycle, from raw material sourcing to recycling content.

These upcoming requirements demand significant preparation in data collection and management. Here are the key information points that will be required:

1. General battery and manufacturer information.
2. Data on the carbon footprint of the manufacturing process.
3. Information on responsible sourcing of materials like cobalt and lithium.
4. Details on the percentage of recycled content used.
5. Information on battery health, durability, and expected lifetime.
6. Instructions for repair, repurposing, and end-of-life handling.

These changes are part of the new Batteries Act landscape. If your business is not already preparing for these changes, you are falling behind. Contact Deutsche Recycling today to build a strategy that ensures you are ready for these complex new demands.

Correctly labeling your batteries is only one part of your legal obligations in Germany. Before placing any batteries on the market, you must complete a mandatory registration with the national register, Stiftung ear (Stiftung Altgeräte-Register). This registration assigns you a unique producer number (WEEE-Reg.-Nr. DE), which must be used on business documents. Operating without this registration is illegal and can lead to fines of up to €100,000.

Furthermore, registration requires that you have a legally compliant take-back solution for used batteries. This is a core principle of Extended Producer Responsibility (EPR). You must either join an existing collective scheme or establish your own system to manage collection and recycling. These systems ensure that the 50% collection rate target for portable batteries is met. Navigating the requirements for a German battery take-back scheme can be complex, but it is an unavoidable legal duty.

The combination of Germany’s BattG and the new EU Battery Regulation creates a complex and dynamic compliance environment. The rules require constant monitoring and swift action to avoid penalties. For many businesses, managing these obligations internally is a drain on resources and carries a high risk of error. A single mistake in labeling or registration can halt your entire EU sales operation.

This is where Deutsche Recycling provides a comprehensive solution. We handle every aspect of your battery compliance, from Stiftung ear registration to managing your take-back obligations and ensuring your labeling is 100% compliant with current and future laws. If you have not yet taken action to meet these regulations, the time to act is now. Contact us for an immediate consultation to secure your legal compliance and focus on your core business. We ensure you understand all legal differences, including WEEE, battery, and packaging laws.