The German Battery Act (BattG) implements EU directives, establishing a strict framework for Extended Producer Responsibility (EPR). This principle makes you, the producer, financially and organizationally responsible for the entire lifecycle of batteries you sell in Germany, including their collection and recycling. The law defines “producer” broadly, including not just manufacturers but also importers and even distributors if the original supplier is not registered. The updated BattG2, effective since January 2021, shifted registration authority to the Stiftung Elektro-Altgeräte Register (stiftung EAR), which already manages WEEE compliance. This change requires active, independent registration for each brand and battery type you place on the market. Data from a previous registration with the Federal Environment Agency (UBA) is not automatically transferred. These regulations are not static; they evolve with EU-level changes, such as the new EU Battery Regulation 2023/1542, which introduces even stricter rules that will be fully in effect by August 2025. To maintain compliance, you need a reliable EPR service provider. The legal landscape demands proactive management, making it essential to address these requirements without delay.

You are considered a producer under the BattG if you are the first to place batteries, or products containing them, on the German market. This includes importing products that are not already registered in Germany by an upstream supplier. The law covers three main categories of batteries, and you must register for each type you sell. It is crucial to correctly classify your products to ensure proper registration and reporting. The law makes no distinction between batteries sold loose or those already installed in devices.

The primary battery categories are:

• Portable Batteries: Sealed batteries that are handheld, such as AA, AAA, and button cells.
• Industrial Batteries: Batteries designed for exclusively industrial, commercial, or agricultural use, including those in e-bikes.
• Vehicle Batteries: Batteries used for starting, lighting, or ignition in vehicles.

A single company may need to manage registrations across all three categories, each requiring specific compliance actions. Understanding your role and the products you handle is the first of many steps, including the need to label batteries correctly. This classification dictates your subsequent obligations, from take-back solutions to reporting quantities.

Before selling any batteries in Germany, you must register as a producer with the stiftung EAR. This registration is a legal permit to access the market and is not optional. The process is handled through the stiftung EAR online portal and requires detailed information about your company and the products you intend to sell. A key upcoming change is that from August 18, 2025, non-German companies must appoint an Authorized Representative (AR) based in Germany to manage their BattG obligations.

The registration process involves several key steps:

1. Create a User Account: Set up an account on the stiftung EAR portal, specifying it is for the Battery Act.
2. Provide Company Details: Submit your company name, address, contact information, and tax numbers.
3. Appoint a Legal Representative: Designate a person authorized to act on behalf of your company.
4. Specify Brand and Battery Type: Register each brand and battery type (portable, industrial, vehicle) you will sell.
5. Join a Take-Back Scheme: For portable batteries, you must provide proof of participation in an approved take-back scheme.
6. Submit and Await Approval: After submission, stiftung EAR reviews the application, a process that can take several weeks.

Upon successful registration, you will receive a unique BattG registration number (e.g., BattG-Reg.-Nr. DE XXXXXX), which must be used in your business dealings. Given the complexities, especially for international firms, managing this process requires careful attention to detail to avoid delays.

Registration is only the first step; you must also ensure a compliant system for battery collection and recycling is in place. The BattG requires producers to finance and organize the take-back of waste batteries, a core component of your EPR duties. For portable batteries, this is typically achieved by joining a government-approved producer take-back scheme. These schemes manage the collection from public collection points and retailers on your behalf. For industrial and automotive batteries, you must offer a reasonable and free-of-charge return option for end-users. Failure to establish a compliant take-back system is a direct violation of the law and can lead to immediate sales prohibitions. The new EU Battery Regulation sets higher collection targets, increasing the pressure on producers to ensure their systems are effective. Choosing the right battery recycling service is therefore not just a compliance issue but a strategic decision to ensure long-term market access. This system underpins your entire compliance strategy, making it a critical focus area.

Non-compliance with the German Battery Act carries severe consequences that can impact your business operations and finances. The German Federal Environment Agency (UBA) can impose fines of up to €100,000 per violation for offenses like failing to register before market entry or not providing a valid take-back solution. Beyond fines, authorities can issue sales bans on your products, forcing you to cease all distribution in Germany. Marketplaces are also increasing their scrutiny; from August 2025, they will be required to verify the BattG registration of sellers on their platforms. This means that without a valid BattG number, your listings on major online platforms could be removed. The risks extend beyond financial penalties to significant reputational damage and loss of consumer trust. The only way to mitigate these risks is to register with stiftung EAR and maintain full compliance. These enforcement measures underscore the urgency of addressing your obligations now.

Navigating the requirements of the BattG and the upcoming EU Battery Regulation demands expert knowledge and continuous attention. Deutsche Recycling offers a comprehensive service to manage all your battery compliance needs, ensuring you are 100% legally compliant. We handle the entire process, from the initial registration with stiftung EAR to appointing an authorized representative and managing your ongoing reporting obligations. Our service is designed to relieve your administrative burden, allowing you to focus on your core business without worrying about complex environmental laws. We provide a clear, efficient path to full compliance, safeguarding your access to the German market. Don’t risk costly fines or sales interruptions. Contact Deutsche Recycling today for an individual consultation and ensure your business meets all regulatory requirements swiftly and effectively.