Recycling lithium-ion batteries: what electromobility companies must know in 2025
The rise of electromobility continues — and e-bikes remain at the forefront of this trend in Germany. Although sales have stagnated since peaking in 2022, the market remains strong, with around 2.1 million e-bikes sold in 2024, maintaining the high level seen the previous year. For the second year in a row, more e-bikes than conventional bicycles were sold nationwide, and e-bikes now account for over 50 percent of total bicycle sales. Among model types, e-mountain bikes are especially popular. Interestingly, while demand remains high, the share of imported e-bikes has declined, with only about 860,000 units imported in 2024 — a significant drop compared to previous years.
As the number of e-bikes in circulation grows, so too does the volume of used lithium-ion batteries — and with it, the regulatory, logistical, and environmental responsibilities placed on companies that manufacture, import, distribute, or sell these products. In this article, we provide a practical overview of your legal obligations in 2025 and how to ensure full compliance with German and EU-wide battery regulations.
What has changed since 2021?
New EU Battery Regulation (Regulation EU 2023/1542)
The EU Battery Regulation, which came into force in August 2023, replaces the outdated 2006 Battery Directive. It will fully apply from 2025 and introduces significantly stricter rules for the entire battery lifecycle, including:
- Mandatory recycling quotas for lithium, cobalt, and nickel by 2031
- Digital battery passports for batteries over 2 kWh (industrial and EV batteries)
- Interchangeability requirement for portable batteries and batteries in light electric vehicles (LEVs) such as e-bikes and e-scooters
- CO₂ footprint declaration for certain battery types
- Due diligence obligations for companies in raw material sourcing
German Battery Act (BattG) – Implementation by August 18, 2025
Germany has aligned the Battery Act (BattG) 2023–2024 with EU requirements. Key changes include:
- Stricter registration obligations for manufacturers – including for cross-border sales
- Increased collection and recycling quotas
- Obligations for online retailers and foreign suppliers via fulfillment service providers
Anyone placing e-bikes, e-scooters, or their batteries on the market in Germany for the first time – whether a manufacturer, importer, online retailer, or leasing provider – is legally considered a “manufacturer” and has extensive obligations.
Your Obligations as a Company in 2025
1. Registration with EAR and a Take-Back System
Companies placing batteries (including built-in ones) on the market must:
- Register with the EAR Foundation for electrical devices
- Join a battery take-back system (from 2026, an organization for manufacturer responsibility)
- Label batteries with the crossed-out trash can symbol and chemical abbreviations
- Keep records of quantities placed on the market and collected
2. Product Design: Interchangeable Batteries Are Mandatory
The EU Battery Regulation requires that batteries in LEVs such as e-bikes and e-scooters must be interchangeable. From 2027, non-interchangeable designs in these battery categories will generally be prohibited (exceptions are rare). The removability and interchangeability of device batteries are also being tightened. With few exceptions, these batteries must be replaceable by end-users or independent economic operators by 2027.
3. Take-Back and Recycling Obligations
- Acceptance of old batteries free of charge in retail or via alternative take-back systems
- Return of industrial batteries (e.g., from e-bikes) to certified recyclers
- Safe transport and storage of lithium-ion batteries according to ADR regulations
- Online retailers must inform consumers about return options; foreign providers are responsible via an authorized representative or fulfillment partner
Common Mistakes to Avoid:
❌ Replacement Batteries Not Registered
Separately sold replacement batteries are not covered by the original product registration. Each battery must be registered individually.
❌ Non-Compliance in Online Sales
Many online sellers fail to meet registration or labeling requirements. Authorities actively enforce compliance: fines up to €100,000, import bans, and marketplace suspensions.
❌ Insufficient Take-Back Systems for Sharing Services
Operators of e-scooter or e-bike fleets must provide easy return options – even when vehicles are decommissioned.
FAQ
Who is considered a manufacturer under BattG?
Anyone who places batteries or products with built-in batteries on the market in Germany for the first time is considered a “manufacturer,” regardless of whether they are a manufacturer, importer, online retailer, leasing, or sharing provider.
What must I complete as a company by August 2025?
- Register with the EAR Foundation
- Join a take-back system (from 2026: organization for manufacturer responsibility)
- Label batteries with symbols and chemical abbreviations
- Document quantities of batteries placed on the market and collected
Do the obligations also apply to built-in batteries?
Yes. Products with built-in batteries (e.g., e-bikes, e-scooters) must also be registered and reported to take-back systems.
Do replacement batteries need to be registered separately?
Yes. Each battery is legally considered an independent product and must be registered individually – including replacement batteries sold separately from the device.
What design obligations for batteries apply to manufacturers?
From 2027, batteries in devices and light electric vehicles (e.g., e-bikes, e-scooters) must be interchangeable. Non-interchangeable designs are generally prohibited (exceptions are rare).
What recycling and take-back obligations exist?
- Retailers and manufacturers must accept old batteries free of charge
- Industrial and vehicle batteries may only be returned to certified recyclers
- Transport and storage of lithium-ion batteries must comply with ADR regulations
- Online retailers must inform customers about return options
What penalties exist for violations?
- Fines up to €100,000
- Import bans
- Suspensions on online marketplaces
What collection and recycling quotas apply?
- Collection quota for portable batteries: 63% by 2027
- Recycling efficiency: 65% for lithium, 95% for cobalt, nickel, and copper (target 2030)
What is the battery passport?
For batteries with more than 2 kWh capacity, a digital battery passport will be mandatory by 2026, containing information on origin, composition, and sustainability.
