The new Battery Act Implementation Act (BattDG) has been in effect in Germany since October 7, 2025. It transposes the European Battery Regulation (EU) 2023/1542 into national law and introduces a key new feature: the Producer Responsibility Organization (PRO) – referred to in Germany as OFH (Organisation für Herstellerverantwortung).
What is an OfH?
The Producer Responsibility Organization is an authorized system that manages and implements the legal obligations related to batteries.
This includes, in particular:
- Take-back of used batterie
- Organization of collection and transport
- Recycling and recovery
- Documentation and legal reporting
Manufacturers: Obligation to join an OfH
Anyone placing batteries on the market in Germany for the first time must join an authorized OfH starting January 1, 2026.
This applies to all battery categories:
- Portable batteries
- Starter batteries
- Industrial batteries
- Batteries for electric vehicles
- Batteries for light vehicles (e.g., e-bikes, e-scooters)
Why this requirement? Manufacturers are responsible for the entire life cycle of their products – from market launch to disposal.
What specific services does an OfH provide for manufacturers?
- Assistance with registration with the EAR Foundation
- Verification of compliance with participation requirements
- Organization of nationwide collection and logistics
- Collaboration with certified disposal and recycling partners
- Volume reporting and reporting to authorities
- Ensuring recycling quotas
- Preparation for future requirements (e.g., carbon footprint, digital battery passport)
The manufacturer finances and commissions – OfH organizes and implements.
Retailers: No obligation to join – but a clear obligation to accept returns
Membership in a collection organization is not mandatory. The acceptance of used batteries, however, is.
Specifically, this means:
- Every retailer who sells batteries must take back used batteries free of charge
- This applies regardless of where the battery was originally purchased
- The obligation applies equally to brick-and-mortar retailers, online retailers, and wholesalers
Additional requirements:
- Provision of collection boxes in the store
- Visible customer information regarding return options
- Online: References to the website or in the product shipment
Important:
The collected batteries must then be handed over to an authorized OfH. Retailers thus become part of the take-back system – even without participating in the system themselves.
The retailer does not contribute financially, but instead uses the OfH as a free disposal service provider to fulfill its own take-back obligation.
What specific services does an OfH provide for retailers?
- Providing collection containers
- Organizing pickups
- Proper disposal and recycling
- Legally compliant handling of take-back processes
The retailer collects – OfH takes care of the rest.
Why the new system is important
Batteries contain valuable raw materials such as lithium, cobalt, and nickel – but they also pose significant risks if disposed of improperly.
- Lithium-ion batteries are a common cause of fires in garbage trucks and sorting facilities
- Recyclable materials are lost when batteries are not recycled properly
- The collection rate in Germany is currently around 50%
The new law establishes:
- clear responsibilities
- a nationwide take-back system
- higher recycling rates
- greater safety in disposal
Conclusion
The OfH is the operational backbone of the new battery law. While manufacturers provide funding and retailers collect batteries, the OfH handles all logistics and ensures proper recycling. This collaborative approach secures valuable raw materials such as lithium and cobalt, minimizes fire risks, and makes the legal take-back obligation practical and legally compliant for all parties involved.
ECOPV-EU is a licensed OfH and offers manufacturers, importers, and retailers a legally compliant comprehensive solution for their take-back obligations.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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