BattDG Guide
A compact explanation of the new Battery Act Implementation Act
The Battery Act Implementation Act (BattDG) has redefined producer responsibility for batteries and accumulators in Germany since October 7, 2025. As the national implementation of the EU Battery Regulation, it requires first-time distributors to join a Producer Responsibility Organisation (PRO) – locally referred to as OfH or Organisation für Herstellerverantwortung – to ensure environmentally sound collection and disposal.
Scope: Which batteries are affected?
The BattDG applies to all types of batteries (primary batteries) and rechargeable batteries (secondary batteries) – regardless of whether they are loose or permanently installed in devices.
Batteries are classified into five categories:
- Device batteries: Encapsulated batteries, compact and portable.
- Light Vehicle (LV) batteries: Sealed, weighing up to 25 kg (e.g., e-bikes, e-scooters).
- Starter batteries: Conventional car batteries for starting, ignition, or lighting.
- Traction batteries: Drive batteries for electric vehicles (EVs).
- Industrial batteries: Batteries for industrial purposes or weighing more than 5 kg.
Who is responsible?
The legal obligation applies to manufacturers as defined by the BattDG. A manufacturer is defined as any entity that commercially places batteries on the market in Germany for the first time. This includes:
- Manufacturers based in Germany.
- Importers who bring batteries from abroad onto the German market.
- Private-label users who sell batteries under their own brand name.
- Online retailers who sell directly to German end users.
Important: Anyone who sells batteries without registration is acting in violation of the law. The resale of unregistered products may also be subject to penalties.
The Core Obligations under the BattDG
To comply with the law, companies must take the following steps:
- Registration with the ear Foundation: Before sales begin, all brands and categories must be registered in the battery registry.
- Membership in a Producer Responsibility Organization (PRO): Manufacturers must join a producer responsibility organization to finance collective take-back.
- Take-back & Disposal: Ensuring that used batteries are properly collected from end users and distributors.
- Deposit Requirement: For vehicle batteries (starter batteries), retailers must collect a deposit and refund it upon return.
- Reporting: Regular reporting of the quantities and weights placed on the market.
Risks Associated with Violations and Non-Compliance
The BattDG imposes strict penalties for violations to ensure fair competition:
Fines: Administrative penalties of up to 100,000 EUR.
Profit forfeiture: Confiscation of revenue generated by non-compliant products.
Sales ban: Immediate ban on sales until registration and participation in the OfH program are verified.
Risk of legal action: Civil lawsuits and costly cease-and-desist letters from competitors.
ECOPV-EU: Officially Authorized Partner for Used Batteries
ECOPV GmbH is an authorized Producer Responsibility Organization (PRO) – locally referred to as OfH or Organisation für Herstellerverantwortung – for waste portable batteries in accordance with Section 8 of the German Battery Act (BattDG) in conjunction with Article 58 of Regulation (EU) 2023/1542 (EU Battery Regulation).
As an OfH, ECOPV-EU GmbH provides the physical infrastructure and logistics necessary to meet legal recycling standards. We offer a direct, free solution for all companies that sell or handle batteries.
What we offer retailers and distributors:
- Free collection containers: We deliver suitable, ADR-compliant collection containers directly to your location at no cost.
- Free pickup service: As soon as your containers are full, our certified logistics partners will pick them up free of charge.
- Safe and legal disposal: We guarantee professional recycling in accordance with the highest environmental and legal standards (BattDG & EU Regulation).
Who can participate?
1. Voluntary collection points pursuant to Article 67 of Regulation (EU) 2023/1542 (schools, associations, businesses)
2. Public authorities or third parties acting on their behalf that carry out waste management operations pursuant to Article 66 of Regulation (EU) 2023/1542;
3. Dealers pursuant to Article 62 of Regulation (EU) 2023/1542
4. Treatment facilities for end-of-life vehicles subject to Directive 2000/53/EC
3 Steps to Becoming a Collection Point
01.
Step 1: Sign up for free
Register a collection or drop-off point easily and for free:
02.
Step 2: Receive confirmation & equipment
After registering, you will receive your confirmation of participation, appropriate collection containers, and all safety information.
03.
Step 3: On-demand pickup
We’ll take care of the free pickup and proper recycling of your used batteries.
Our Service
ECOPV-EU provides expert support to help you comply with German regulations and, if desired, handles the entire process of implementing and registering the batteries you plan to bring to market.
All you need to do is submit the required quantity data to ECOPV-EU, then sit back and let us do the work for you.
Specific requirements for manufacturers
Registrations
Just as with electrical appliances, batteries are subject to a registration requirement, which is handled by the ear Foundation. Batteries are categorized here by type and chemical composition.
In addition
An additional registration is required for a self-collection system. This ensures a fair allocation of costs for the collection, sorting, and treatment of used batteries collected nationwide, based on the volume of input.
Quantity reports
Depending on the selected battery return system and the company’s own products, the quantities placed on the market must be reported monthly, quarterly, or simply annually.
FAQ
Who is subject to the Battery Act Implementation Act?
In Germany, until the new EU Battery Regulation enters into force, the Battery Act applies to all entities that place batteries on the market.
Are retailers in Germany required to accept used batteries or rechargeable batteries for disposal in their stores?
Battery distributors (retailers) are required to accept used batteries from end users free of charge. On the other hand, end users are legally required to return all used batteries to battery distributors or to collection points at municipal recycling centers or mobile hazardous waste collection units.
Where do you need to report the sale of batteries?
Before a manufacturer or its authorized representative places batteries on the market as a standalone product or as part of another product, it must register with the ear Foundation.
Why shouldn't batteries be thrown away with household trash?
Batteries are often damaged in waste compactors and catch fire explosively. There are no statistics on how often this happens. The industry estimates that there are a double-digit number of fires per day.
The Battery Law Implementation Act (BattDG)
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