Separate the reporting year from the submission year
Germany’s Environment Agency (UBA) updated its battery-reporting guidance on 9 October 2026. The page distinguishes documentation for 2025 from the requirements applying from reporting year 2026. A webpage update does not establish that a new law took effect that day. UBA guidance
Producers and producer responsibility organisations have different roles
Under section 26 BattDG, a producer responsibility organisation (OfH) submits its annual documentation to the UBA by 30 June. It covers the preceding calendar year. Producers must supply their OfH with the information it requests to fulfil these duties. This does not mean every producer must send the same report directly to the UBA. Section 26 BattDG
Treatment and recycling operators have their own reporting duties
Section 29 addresses waste-management operators treating waste batteries and recycling operators. Depending on their role, the documentation covers incoming quantities, treatment routes, recycling efficiency or material recovery. Their annual deadline is also 30 June, with figures relating to the preceding year. Where recycling involves multiple plants, the first recycling operator is responsible for the documentation; subsequent plants provide the necessary data. Section 29 BattDG
Recommended preparation for businesses
We recommend coordinating compliance, sales and the relevant service partners:
- Record your role: producer, OfH or operator.
- Appoint a data owner and establish an internal timetable for reporting year 2026.
- Agree data fields, supporting records and contacts with your OfH or operator.
- Resolve differences between internal and partner data before submission.
These steps are editorial recommendations for organising the work. The applicable duties depend on the actor’s role and the current official requirements.
Research date: 12 October 2026. UBA page updated: 9 October 2026. For documentation covering 2026, the annual deadline referring to the preceding year generally falls in 2027. Other producer obligations require a separate assessment.
