info@ecopv-eu.com
+49 6196 5835357
info@ecopv-eu.com
+49 6196 5835357
All questions regarding battery registration, the EAR Foundation, the Battery Act (BattDG), and the placing on the market of energy storage devices. This detailed guide answers your questions about the legally compliant implementation of battery regulations for batteries, rechargeable batteries, and device-integrated energy storage devices in Germany.
Basics & Legal Framework
The Battery Act Implementation Act (BattDG) regulates the placing on the market, labeling, take-back, and recycling of batteries and rechargeable batteries in Germany. It took effect on October 7, 2025, and completely replaced the old Battery Act (BattG).
As a national implementing law, it transposes the overarching EU Battery Regulation into German law. The BattDG specifies the specific responsibilities of the EAR Foundation as the registration authority, regulates the obligations of market participants, and defines sanctions and fines. While the EU Regulation sets product-specific standards, the BattDG governs the enforcement structure under waste management law and the monitoring of collection rates in the German market.
The BattDG marks a systemic change: It expands the battery classes from three to five categories, requires manufacturers in all sectors to cooperate with a Producer Responsibility Organization (PRO), and significantly tightens monitoring requirements.
Under the old BattG, collective take-back systems were mandatory only for portable batteries. The BattDG extended this requirement to participate in such systems to all battery types. All existing registrations had to be updated by January 15, 2026, on the EAR portal to include chemical compositions and tax ID numbers; accounts that were not updated were blocked. In addition, consumer rights were strengthened, as e-bike and e-scooter batteries can now be dropped off at municipal recycling centers nationwide free of charge.
The EU Battery Regulation (EU) 2023/1542 is a law that applies directly throughout Europe and covers the entire life cycle of batteries. The German BattDG serves as a national supplement to regulate enforcement by authorities and the levels of penalties in Germany.
The EU Regulation harmonizes the European single market through requirements such as the upcoming digital battery passport (starting in 2027) and minimum recycling rates. Since an EU regulation leaves no room for national discretion, Germany uses the BattDG solely to regulate the infrastructure: It entrusts the EAR Foundation with platform management and regulates the approval process for private-sector take-back systems (PRO).
The law divides batteries into five classes: portable batteries, starter batteries, industrial batteries, electric vehicle batteries, and LV batteries (for light vehicles). Each category is subject to specific collection and labeling rules.
This classification primarily serves to precisely distinguish modern e-mobility. Newly introduced are LV batteries (for light vehicles, e.g., e-bikes and e-scooters) as well as electric vehicle batteries (traction batteries), which were previously inaccurately classified as industrial or portable batteries. For manufacturers, error-free classification in the EAR portal is critical, as expanded physical labeling – such as capacity information and the “non-rechargeable” label – has been mandatory on the product for equipment and light vehicle batteries since August 18, 2026.
Manufacturers, Registration, and Authorized Representatives
A manufacturer is defined as anyone who first makes batteries or rechargeable batteries – whether sold separately or built into devices – commercially available on the German market. This applies to traditional manufacturers, importers, and online retailers who import goods directly from abroad.
The term draws a strict distinction between physical manufacturing and market introduction. If a company sells imported electrical devices (e.g., laptops with built-in rechargeable batteries) or sells third-party goods under its own brand, it is legally considered a battery manufacturer. Pure resellers who source goods from suppliers already registered in Germany do not bear any manufacturer responsibility.
Registration is conducted entirely online via the EAR portal. It requires you to provide company information, the brand, the specific battery category, and the chemical composition of the cells, as well as proof of affiliation with a PRO system.
Only after all data and the contract with an approved Producer Responsibility Organization (PRO) have been uploaded to the portal and verified by the EAR Foundation will the official registration number be issued. Prior to this, any offering or sale of batteries in Germany is illegal. Since the verification of OfH contracts is fully automated, incomplete applications result in immediate rejection.
Yes. Companies without a branch office in Germany cannot register themselves on the EAR portal. They are required to appoint an authorized representative based in Germany.
The authorized representative handles registration, monthly reporting, and communication with the authorities. Legally speaking, the authorized representative bears full and legally binding liability to the EAR Foundation for the fulfillment of all waste management obligations of the foreign manufacturer. Foreign accounts that did not designate a domestic authorized representative during the transition to the BattDG were deleted. EPR service providers such as ECOPV-EU often assume this authorized representative role for foreign solar and electronics suppliers on a bundled basis for both WEEE and batteries.
Producer Responsibility Organization (PRO)
A PRO is a government-approved, collective waste management system. Through it, battery manufacturers fulfill their legal take-back and recycling obligations without having to establish their own recycling infrastructure. Since the BattDG took effect, participation in this system has been legally mandatory for all five battery categories.
The PRO handles the operational collection logistics, empties collection boxes at retail locations and municipal recycling centers, and oversees proper recycling. The costs are financed through manufacturer fees. The BattDG put an end to the old practice of placing certain battery classes (such as industrial or starter batteries) on the market without such a collective system.
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.
Labeling & Product Requirements
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.
Battery Categories in Detail
Portable batteries are sealed batteries for portable consumer goods (e.g., smartphones, remote controls, power tools) that an average consumer can easily hold in their hand. Industrial batteries are intended for commercial, industrial purposes, or stationary storage systems (e.g., PV battery storage).
The distinction is primarily based on weight and intended use. Batteries are considered consumer batteries if they weigh less than 5 kilograms and are not classified as low-voltage, starter, or electric vehicle batteries. Industrial batteries include any battery designed for industrial use or weighing more than 5 kilograms that does not fall into any other category.
Electric vehicle batteries (traction batteries) are batteries specifically designed to power road and rail vehicles (e.g., electric cars, electric buses, electric trucks). Due to their enormous energy density, they are subject to the strictest requirements under all battery regulations.
This category is strictly distinguished from the smaller batteries used in e-bikes. Under the EU regulation, electric vehicle batteries are subject to stricter requirements regarding traceability, carbon footprints, and minimum quotas for the use of recycled raw materials (e.g., cobalt, lithium, nickel). Since these batteries often retain high residual capacity after use in vehicles, the law also sets requirements for a “second life” as large-scale stationary storage systems before final recycling takes place.
LV batteries (Light Vehicles) constitute a separate category for batteries used to power light vehicles (e.g., e-bikes, e-scooters, e-mopeds). Consumers can return them free of charge at municipal recycling centers and bicycle shops nationwide.
This separate category corrects the previous, dangerous classification as harmless device batteries. Due to the significant fire risks posed by damaged lithium-ion batteries of this size, LV batteries are subject to strict transportation and separate recycling requirements. Since August 18, 2026, all new LV batteries placed on the market must also bear expanded visual markings indicating capacity and service life. Manufacturers and importers of electric two-wheelers must register a specialized PRO connection in the EAR system.
Take-Back & Consumers
Retailers that carry batteries in their product range must accept used batteries of the respective category from consumers free of charge and without any obligation to purchase (0:1 take-back).
The take-back obligation applies directly to the point of sale or the online store. For example, if a retailer sells portable batteries, they must provide clearly visible collection boxes for them in the store. In distance selling, take-back must be handled through free return options or collection point networks. Retailers are jointly liable if they offer products from manufacturers that do not have a valid registration in the EAR Register; this results in immediate cease-and-desist letters and sales bans.
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.
Interfaces & Miscellaneous
A battery-powered electrical device triggers two parallel EPR obligations. WEEE registration is required for the device itself, and a separate battery registration – including a connection to the PRO – is required for the battery contained in or attached to the device.
Manufacturers of products such as battery-powered screwdrivers, smartphones, or PV storage systems must complete two separate registration processes on the EAR Foundation’s portal. The ongoing monthly reporting requirements and the labeling requirements on the product must also be fulfilled separately for both laws. Full-service providers bundle these processes to cut the bureaucratic burden in half.
The sale of batteries without valid registration on the EAR portal is illegal. It is punishable by fines of up to 100,000 euros, immediate sales bans, and the confiscation of all sales proceeds.
In addition to penalties imposed by the Federal Environment Agency, unregistered companies face immediate warnings under competition law from competitors or industry associations. Since a violation of the BattDG constitutes a breach of market conduct, competitors can seek injunctions and damages through the courts. Online marketplaces automatically suspend merchant accounts if battery registration numbers are missing or incorrect in order to avoid liability themselves.
Service Provider/Support
As a full-service provider based in Eschborn, we handle all legal and operational aspects of the BattDG for manufacturers and importers. Since we ourselves are an approved take-back system (PRO) for used batteries, our services include direct system integration, EAR registration, battery class classification, and monthly reporting.
We coordinate all steps in accordance with the ElektroG, ensuring that solar providers, e-commerce retailers, and electronics manufacturers receive their entire EPR compliance from a single source. For foreign market participants without a German branch office, we also assume the legally required role of domestic authorized representative.
We look forward to your message!