Germany’s Battery Act (BattG) establishes legal responsibility for the entire lifecycle of batteries sold within the country. The law defines a ‘producer’ as any entity that first places batteries on the German market, affecting thousands of manufacturers, importers, and online retailers. This extended producer responsibility (EPR) requires your company to manage products beyond the point of sale, with over 50% of portable batteries requiring collection. You must register with the official body, Stiftung EAR, before a single product is sold. Ignoring this first step is a direct violation leading to immediate penalties. Understanding your role is critical, as the law makes no distinction between B2B or B2C sales channels. These regulations set the stage for even broader rules across the entire European Union. Find out more about the Batteries Act and its impact.

The new EU Battery Regulation (2023/1542) will replace existing national directives on August 18, 2025, creating a single, stricter legal framework. This regulation introduces five new battery categories and expands producer obligations significantly. One of the most critical changes is the mandatory appointment of an Authorised Representative (AR) for any producer not established in Germany. By the August 2025 deadline, all registrations for foreign companies without an AR will be cancelled. The regulation also mandates new labeling, including the CE mark, to certify compliance with EU safety and environmental standards. These changes are not optional; they are legally binding and require immediate preparation. Keep up with the latest on the new battery regulation to stay ahead.

Compliance begins with one critical action: registering as a producer with the Stiftung Elektro-Altgeräte Register (EAR). This process is not automatic and can take over 3 weeks to complete, so early action is essential. You must register each brand and battery type you intend to sell in Germany. The registration assigns you a unique BattG registration number, which is your license to operate. For portable batteries, you must also connect to an approved take-back scheme. Here is the typical registration flow:

• Create a user account in the Stiftung EAR online portal.
• Provide detailed company information and appoint legal representatives.
• For foreign companies, formally appoint an authorized representative based in Germany.
• Specify each brand and battery type (portable, industrial, or automotive) you will place on the market.
• Submit the application and await your official registration number before starting sales.

This registration is the foundation of your legal compliance in Germany. You can learn more about how to register with a take-back scheme.

Failing to license batteries for electronic products in Germany carries severe consequences that can halt your business operations. The German Federal Environment Agency (UBA) can impose fines of up to €100,000 for violations like failing to register. Beyond fines, authorities can issue sales bans on all your products, effectively removing you from the market. Many online marketplaces are now required to verify your EPR registration number, blocking non-compliant sellers automatically. These financial and operational risks are substantial and entirely avoidable. The legal framework is designed to hold every single producer accountable. You can get a compliance provider to manage these risks effectively.

Proper labeling is a core requirement of the BattG, providing consumers with essential disposal information. All batteries must display the crossed-out wheeled bin symbol, indicating they cannot be disposed of in household waste. For batteries containing more than 0.0005% mercury, 0.002% cadmium, or 0.004% lead, the corresponding chemical symbols (Hg, Cd, Pb) must be printed below the bin. This labeling is not just a suggestion; it is a legal mandate checked by market surveillance authorities. Producers are also obligated to inform consumers about battery return options. These steps ensure transparency and contribute to achieving Germany’s high collection targets. For detailed guidance, see our page on how to label batteries.

For companies without a physical presence in Germany, appointing an Authorized Representative (AR) is a mandatory step for compliance. As of August 18, 2025, it will be impossible for a foreign company to be registered for batteries without one. The AR takes on the legal responsibilities of the producer within Germany, managing registration, reporting, and communication with authorities like Stiftung EAR. This ensures there is a legal entity within the country that can be held accountable. An AR is your legal foothold in Germany, handling 100% of your EPR obligations on the ground. This requirement simplifies enforcement for German authorities and is a non-negotiable part of market entry. Find out how to appoint an authorized representative for your business.

The deadlines are fixed, and the penalties for non-compliance are severe. You must take action now to license batteries for electronic products in Germany. Waiting until the 2025 deadline will disrupt your sales and expose your business to significant legal risk. Deutsche Recycling offers a complete service to manage your obligations under the BattG and the new EU Battery Regulation. We handle everything from registration and authorized representation to reporting and take-back solutions. By partnering with us, you achieve 100% legal certainty and can focus on your core business. Do not delay. Contact Deutsche Recycling today for a consultation and secure your access to the German market.