The new Battery Act Implementation Act (BattDG), which has been in effect since October 7, 2025, has fundamentally redefined the framework for the collection of used batteries in Germany. Today, the Organization for Manufacturer Responsibility (OfH) is the key component for market compliance.
OfH: The Central Take-Back System
Manufacturers, distributors, and importers are required to join an authorized collection organization for most battery categories. Those who place batteries on the market can generally no longer fulfill their Extended Producer Responsibility (EPR) obligations independently but must be part of an authorized collection system.
This applies to the following categories:
- Portable batteries & LVB (light vehicles): Membership in a collection organization is mandatory here. These batteries must be returned through the collective systems.
- Starter, industrial, and electric vehicle (EV) batteries: Here, too, the OfH is the central instrument. However, the law continues to permit individual systems in these three categories under very strict conditions. These must, however, be approved by the competent authority (Stiftung EAR) and meet the same high requirements for financing and logistics as an OfH.
What can a OfH do for your company?
- OfH acts as your operational arm in the circular economy. It ensures that all legal requirements are fully met:
✅ Nationwide take-back: OfH coordinates collection at drop-off points (e.g., in retail stores or at municipal facilities) and ensures proper logistics and recycling.
✅ Financial security: OfH ensures that disposal costs are covered even in the event of the manufacturer’s insolvency (usually through collective guarantee systems).
✅ Reporting: OfH aggregates its members’ volume reports and submits them to the EAR Foundation.
This saves companies the significant effort of reporting every single volume of products placed on the market and collected in detail themselves.
No market access without proof of OfH:
Proof of OfH participation is a prerequisite for valid registration on the EAR portal. Without active registration, distribution is prohibited.
Legal certainty with ECOPV-EU
To operate safely in the long term within this highly regulated environment, you need a reliable expert. ECOPV-EU is an authorized collection organization and offers manufacturers, importers, and distributors 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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