German battery legislation is currently in a transitional phase. While the old Battery Act (BattG) is being phased out, the new BattDG and the EU Battery Regulation (EU) 2023/1542 are governing the market.
However, a key step regarding labeling requirements – scheduled for August 2026 – has been delayed.
What are the current requirements?
For the time being, the established labeling rules continue to apply to manufacturers and importers:
- Capacity labeling: Vehicle and equipment batteries must bear a visible, legible, and indelible capacity label before being placed on the market for the first time.
- Waste bin & heavy metals: The crossed-out waste bin symbol and the marking “Cd” (cadmium > 0.002%) or “Pb” (lead > 0.004%) are mandatory.
- CE marking: The requirements for CE marking are derived from the conformity provisions of the EU Battery Regulation.
What is expected to take effect as of August 18, 2026?
Article 13, paragraphs 1 through 3, of the EU Battery Regulation provides for extensive additional labeling requirements. The following were specified:
• Battery category and battery identification
• Place of manufacture
• Date of manufacture (month and year)
• Weight
• Capacity
• Chemical composition
• Certain hazardous substances
• Suitable fire extinguishing agent
• Critical raw materials with a mass fraction exceeding 0.1%.
For certain battery categories, additional information is required, such as capacity or – in the case of non-rechargeable portable batteries – minimum operating time and the designation “non-rechargeable.”
Why Is there a delay?
Implementation is being held up by pending legislation from the European Commission:
- An implementing act is required to specify the exact layout, format, and symbols for the labels.
- The European Commission was required to adopt these final layout specifications by August 18, 2025 – exactly one year before the planned start date for businesses. This deadline was not met.
- Although a draft is now available, it is still undergoing the legislative process and has not yet been adopted as a legal act.
When will the requirements take effect?
A specific postponement to a particular month or half-year is not currently stipulated by law.
The applicable rule is: August 18, 2026, or 18 months after the implementing act enters into force.
The actual effective date can therefore only be determined once the implementing act has been adopted and published.
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