Sprache: DE
What does the Battery Law Implementation Act (BattDG) regulate – Germany?
What is the BattDG?
The Battery Law Implementation Act (BattDG) is the current national implementation of the EU Battery Regulation (EU) 2023/1542 in Germany and replaces the former German Battery Act (BattG). It harmonises German law with EU requirements.
The BattDG came into force on October 7, 2025 and replaced the German Battery Act that had been in effect since 2009.
Why was the BattDG introduced?
Germany had to adapt its national battery law to the new EU Battery Regulation, which has applied directly since February 18, 2024 and contains comprehensive requirements for sustainability, life cycle, collection rates and recycling of batteries.
The BattDG serves to:
- implement the provisions of the EU Regulation into German law,
- define the duties of national authorities,
- and regulate national provisions where the EU Regulation allows discretion.
Which types of batteries does the BattDG distinguish?
Under the old Battery Act, there were three main battery categories. The BattDG expands this structure under EU requirements, for example to:
- portable batteries,
- starter batteries,
- industrial batteries,
- batteries for light means of transport (LV batteries),
- batteries for electric vehicles.
This categorisation enables more differentiated regulation of take-back, disposal and recycling.
What obligations apply to manufacturers and importers?
Under the BattDG, expanded and in some cases stricter obligations apply:
Registration and market surveillance
- Manufacturers and importers must register with stiftung ear (the foundation that runs the register) before they may place batteries on the market.
Expanded definition of “manufacturer”
- The BattDG broadens the definition to include traders acting intentionally or negligently in placing batteries from improperly registered sources on the market.
Organisational obligations
- There is an obligation to participate in systems for take-back and recycling according to the new battery categories.
What changes apply to the take-back of waste batteries?
The BattDG provides for more extensive take-back obligations than the old German Battery Act:
- Dealers must take back all batteries they sell or have sold free of charge – regardless of whether a new battery is purchased.
- Municipal collection points are to accept batteries such as those from e-bikes or e-scooters.
- Public waste management bodies have expanded acceptance obligations (partly as of January 1, 2026).
These rules are intended to ensure comprehensive and consumer-friendly return options for all battery types.
Which elements from the old Battery Act remain?
Some fundamental principles of producer responsibility from the former Battery Act remain, such as manufacturer responsibility for take-back and recycling. However, these are adapted to the broader requirements of the EU Regulation and the BattDG.
Authorised representative under the BattDG
- Definition
An authorised representative is a natural or legal person based in Germany who has been authorised in writing by a manufacturer to fulfil certain obligations on behalf of the manufacturer under the BattDG.
- Legal position
The authorised representative assumes responsibility for compliance with the manufacturer’s legal obligations regarding placing batteries and accumulators on the German market.
Labelling obligations under the BattDG
The EU Battery Regulation 2023/1542 sets out comprehensive labelling requirements, either on the battery itself or on its packaging, including, for example:
- type and chemical system of the battery,
- capacity (for rechargeable batteries: rated capacity in mAh or Ah),
- date of manufacture,
- CE marking,
- symbol for separate collection (crossed-out wheeled bin),
- hazardous substances (e.g. Hg, Cd, Pb – if present).
In addition, notices on removability, disposal, and where applicable on performance and service life are mandatory.