BattDG Guide
A compact explanation of the new Battery Act Implementation Act

Yes. For each of the five statutory battery categories in which your company sells products, an active system contract with a authorized PRO must be on file in the EAR portal.

Since the recycling processes for a heavy electric vehicle battery differ fundamentally from those for a coin cell (appliance battery), PRO systems are usually certified on a category-specific basis. Electronics or solar providers with a broader product range therefore often have to enter into contracts with different PRO partners and manage them individually. Full-service providers bundle these contracts to minimize the administrative burden on manufacturers.

Anyone who fails to provide proof of a valid PRO contract on the EAR portal will lose their manufacturer registration. Any further offering or sale of the affected batteries in Germany is illegal from that moment on.

The EAR Foundation imposes strict penalties for the absence of a PRO contract. Providing proof of participation in the system is an ongoing obligation: For new applications, the absence of a PRO contract results in immediate rejection of the registration. For existing registrations, active participation in the system must be fully documented in the EAR portal for the current calendar year (as well as in advance for the following year). If a contract is terminated or not renewed in a timely manner, the authority will immediately revoke the registration. This results in automatic account suspensions on online marketplaces, and legal distribution will only be possible again after a time-consuming repeat of the registration process.

With a PRO affiliation, manufacturers collectively transfer their recycling obligations to an existing collection network. With a company’s own take-back program, the company must organize the return, logistics, and recycling of used batteries entirely on its own and obtain official approval.

An approved in-house take-back system is worthwhile almost exclusively for large corporations with closed B2B distribution cycles – such as automakers with their own service center networks for powertrain batteries. For small and medium-sized businesses as well as e-commerce companies, establishing a nationwide infrastructure is economically unfeasible. They typically use the PRO affiliation to easily meet legal requirements.

No, generally not. The BattDG does not require individual manufacturers to provide an individual insolvency-proof guarantee. Instead, the financial security for recycling is addressed collectively through mandatory membership in a Product Responsibility Organization (PRO).

While the ElektroG requires separate financial security for each B2C manufacturer, the battery law shifts financial liability to the collective system of the PRO. PRO providers must demonstrate to the EAR Foundation that they can permanently finance take-back and recycling even in the event of individual members’ insolvency. Manufacturers pay regular recycling fees to their PRO for this purpose. Individual financial security must be deposited directly with the EAR only if a large corporation operates an officially approved in-house take-back system.

Batteries must be permanently marked with the crossed-out trash can symbol. In addition, chemical symbols (Hg, Cd, Pb) must be printed on the battery if the threshold values for mercury, cadmium, or lead are exceeded.

The labeling must be clearly visible and affixed directly to the battery; it may only be printed on the packaging if there is an acute lack of space. Since August 18, 2026, portable batteries and low-voltage batteries must also provide information on their capacity, minimum service life, and the label “not rechargeable” (if applicable). More comprehensive requirements, such as the carbon footprint or the QR code for the digital battery passport, will follow in the coming years.

Yes, as of February 18, 2027. By this deadline, nearly all device batteries and batteries for light vehicles (LV batteries) must be designed so that end users can remove and replace them on their own without damaging the device.

This EU requirement is intended to extend the lifespan of electronic products and reduce electronic waste. For manufacturers, this means significant changes to product design, as permanently glued-in batteries in smartphones, laptops, or power tools will soon be banned. Products newly introduced to the market starting in February 2027 must be built so that the battery can be replaced using standard tools. Exceptions apply only to a very small number of device categories where waterproofing or data security absolutely require a permanent seal.

The Declaration of Conformity is a legally binding document through which the manufacturer or importer officially confirms, prior to the product’s launch, that the battery meets all safety, environmental, and labeling requirements of the EU Battery Regulation and the German Battery Act (BattDG).

By affixing the CE marking and issuing the Declaration of Conformity, the company assumes full legal responsibility for the product’s compliance. This requires that laboratory tests and technical documentation regarding the chemical composition be available behind the scenes. The declaration does not have to accompany every product, but it must be available for immediate presentation to market surveillance authorities in the event of an inspection. If the document is missing or contains errors, the company faces sales bans and fines.

Consumers can drop off all used batteries free of charge at retail collection points and at municipal recycling centers.

For standard household batteries, collection boxes are available nationwide in supermarkets, drugstores, and home improvement stores. Larger rechargeable batteries – especially heavy batteries for light vehicles (LV batteries such as e-bike batteries) and industrial batteries – can be dropped off at municipal recycling centers nationwide. Due to the acute fire hazard posed by lithium-ion batteries, consumers must tape over the terminals before disposal and report any damaged batteries separately to staff. Disposal in household trash is strictly prohibited.