The new EU Battery Regulation and the German Battery Implementation Act (BattDG) have significantly tightened the rules governing the placing on the market of batteries and battery-powered devices.
❓ What has changed since 2025?
The new BattDG has been in effect since 2025. It supplements the EU Battery Regulation at the national level.
- Focus: The regulation no longer covers only disposal, but the entire life cycle (circular economy).
- Recycling: Significantly higher recovery rates apply to raw materials such as lithium, cobalt, and nickel.
❓ Who is affected?
It doesn’t just affect the factories that manufacture batteries.
The following are considered manufacturers under the BattDG:
- Producers: Anyone who manufactures batteries in Germany.
- Importers: Anyone who imports batteries (including those in devices such as laptops, e-bikes, or power tools) into Germany from non-EU countries (e.g., China or the U.S.).
- De facto manufacturer: Anyone who sells batteries under their own brand name (private labeling).
- Foreign retailers without a German branch (in this case, the appointment of an authorized representative is mandatory)
❓ Which batteries are regulated?
Since 2025, the law has distinguished between five categories:
- Portable batteries: Household batteries, button cells.
- LMT batteries: “Light Means of Transport,” e.g., for e-bikes and e-scooters.
- Starter batteries: Conventional automotive batteries.
- Industrial batteries: Stationary storage systems, backup systems.
- Electric vehicle batteries
❓ Which compliance steps are mandatory?
To remain eligible for sale, two requirements must be met:
- Registration: Every manufacturer must have a valid registration number (Batt-Reg. No.) with the ear Foundation. Without this number, an immediate sales ban applies.
- Take-back system: Registration alone is not sufficient. You must join an approved producer responsibility organization (OfH) (e.g., ECOPV-EU). This organization will handle the collection and recycling on your behalf.
❓Do I need to register batteries that are permanently installed in small electrical appliances under both the WEEE Directive and the BattDG?
Yes. The device itself must be registered in accordance with the Electrical and Electronic Equipment Act (WEEE), but the battery it contains must be registered separately with the ear Foundation in accordance with the Battery Act (BattDG).
These are two separate legal obligations, each with its own reporting and disposal procedures.
❓ What happens in case of violations?
- Fines of up to €100,000.
- Full confiscation of the profits generated.
- A permanent ban on trading.
❓As an online retailer, am I required to accept returns of my customers’ batteries free of charge?
Yes, retailers are required to accept used batteries free of charge at their place of business (or, in the case of mail-order businesses, through a return system), provided they carry batteries in their product range.
Yes. Any company that does not have a registered office in Germany but sells batteries directly to end users here must appoint an authorized representative.
❓ The Digital Battery Passport: What’s coming on February 18, 2027?
As of this effective date, the digital passport will become mandatory for electric vehicle batteries, LMT batteries, and industrial batteries (2 kWh and above).
- QR Code: Each battery must bear a physical code that links to the digital record.
- Content: It includes the carbon footprint, chemical composition, evidence of due diligence in the supply chain, and dynamic State of Health (SoH) data.
❓Why is classification (e.g., LMT) so critical?
Incorrect classification is costly. LMT batteries have their own administrative requirements and fees. Anyone who incorrectly classifies an e-bike battery as a standard portable battery is acting in violation of competition laws and risks having to pay back taxes and fines.
❓At what capacity does a battery qualify as an LMT battery rather than a portable battery?
The key factor is the intended use: Batteries for vehicles such as e-bikes, e-scooters, or cargo bikes fall under the LMT category, regardless of their exact watt-hour rating, provided they are intended to power these “light vehicles.”
❓Who is responsible for issuing the battery passport — the battery cell manufacturer or the distributor?
The person responsible is the one who first places the battery on the EU market. They must ensure that all data from suppliers (cells, raw materials) is compiled in the passport.
❓Do I also need to report the batteries in my spare parts?
Yes. Every battery that is placed on the market in Germany for the first time — whether permanently installed in a device, included as an accessory, or sold as a separate replacement part—is subject to reporting and fee requirements.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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