BattDG Guide: The new Battery Implementation Act explained in a nutshell
Since October 7, 2025, the Battery Implementation Act (BattDG) has redefined manufacturer responsibility for batteries and accumulators in Germany. As the national implementation of the EU Battery Directive, it obliges initial distributors to participate in a manufacturer responsibility organization (OfH) to ensure environmentally sound take-back and disposal.
Scope of application: 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.
They are classified into five categories:
- Device batteries: Encapsulated batteries, handy and portable.
- LV batteries (light vehicles): Sealed, weighing up to 25 kg (e.g., e-bikes, e-scooters).
- Starter batteries: Classic car batteries for starting, ignition, or lighting.
- Traction batteries: Drive batteries for electric vehicles (EV).
- Industrial batteries: Batteries for industrial purposes or weighing more than 5 kg.
Who is responsible? (Initial distributor)
The legal obligation applies to manufacturers as defined by the BattDG. This includes anyone who commercially supplies batteries in Germany for the first time. This includes:
- Producers based in Germany.
- Importers who bring batteries from abroad onto the German market.
- Private label users who sell batteries under their own name.
- Online retailers who sell directly to German end users.
Important: Anyone who sells batteries without registration is acting unlawfully. The resale of unregistered products may also be subject to sanctions.
The core obligations under the BattDG
In order to comply with the law, companies must implement the following steps:
- Registration with the ear foundation: Before sales begin, all brands and classes must be registered in the battery register.
- Joining an OfH: Manufacturers must join a producer responsibility organization to finance collective take-back.
- Take-back & disposal: Ensure that used batteries are taken back properly by end users and distributors.
- Deposit requirement: For vehicle batteries (starter batteries), resellers must charge a deposit and refund it upon return.
- Reporting: Regular reporting of the quantities and weights placed on the market.
Risks associated with non-compliance and violations
The BattDG provides for severe penalties for violations in order to ensure fair competition:
Fines: Administrative penalties of up to EUR 100,000.
Profit skimming: Confiscation of revenues generated by non-compliant products.
Sales ban: Immediate sales ban until registration and OfH participation are proven.
Risk of warning letters: Civil lawsuits and costly warning letters from competitors.
ECOPV-EU GmbH is an approved organization for producer responsibility (OfH) for waste batteries from appliances.
ECOPV GmbH is an approved organization for producer responsibility (OfH) 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 a “system operator,” we offer all collection and return point operators in Germany free collection of waste portable batteries. Our goal is to close the loop on valuable resources, ensure safe, environmentally friendly, and efficient take-back, and guarantee high-quality recycling of waste portable batteries—nationwide, transparently, and reliably.
Who can participate?
Voluntary collection points in accordance with Article 67 of Regulation (EU) 2023/1542 (schools, associations, companies);
Authorities or third parties acting on their behalf that carry out waste management measures in accordance with Article 66 of Regulation (EU) 2023/1542;
Dealers in accordance with Article 62 of Regulation (EU) 2023/1542;
Treatment facilities for end-of-life vehicles subject to Directive 2000/53/EC;
Treatment facilities for waste electrical and electronic equipment subject to Directive 2012/19/EU.
What does ECOPV offer?
– Free provision of suitable, ADR-compliant collection containers;
– Free collection of the collected waste batteries by certified logistics partners;
– Safe transport, fulfillment of recycling requirements in accordance with Articles 70 and 71 of Regulation (EU) 2023/1542, and disposal in accordance with the legal requirements of BattDG (§§ 11, 23) and ADR;
– Provision of information and safety materials for all participating collection points.
Safety and environment
All transport is carried out in accordance with the requirements of the ADR regulations. Collected waste batteries are separated according to chemical systems, professionally recycled, and returned to the material cycle. In this way, we ensure that valuable raw materials are recovered and environmental impact is minimized – in line with the objectives of § 13 BattDG to increase the collection rate and conserve resources.
How does participation work?
Register collection or return points easily and free of charge:
www.ecopv-eu.com/batterie-sammelstelle-werden/ or click here
After registering, you will receive confirmation of participation, the appropriate collection containers, and all relevant safety information.
Contact: info@ecopv-eu.com | www.ecopv-eu.com
Our Service
ECOPV-EU provides professional support in compliance within the framework of German law and can take over the complete registration and compliance of the batteries you plan to put on the market. Our BattG service includes all the relevant aspects. As well as submitting the quantities declaration to ECOPV-EU, you can take it easy and let us get to work for you.
Specific requirements for manufacturers acc. to BattG
Registrations
Just like with electronic devices, there is a registration requirement for batteries, which is done through the Stiftung ear. Batteries are categorized here according to battery type and the respective chemical system of the batteries.
Additionally
Additionally, another registration is required for a proprietary take-back system. This ensures a fair cost distribution for the collection, sorting, and treatment of used batteries, which are taken back nationwide based on the input quantity.
Quantity reports
Depending on the selected battery take-back system and your own products, the quantities placed on the market are requested monthly, quarterly or simply annually.
The german battery law (BattG)
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FAQs
Who is subject to the Battery Act?
In Germany, the Battery Act applies to all parties that put batteries on the market up to the entry into force of the new EU Battery Regulation.
Where do you have to register the sale of batteries?
Before a producer or his authorized representative places batteries on the market as a stand-alone product or as part of another product, he must register at Stiftung ear.
Are retailers in Germany obliged to take back used batteries or rechargeable batteries in their stores?
Distributors (retailers) of batteries are obligated to take back used batteries free of chage from the end user. On the other hand, end users are legally obliged to hand in all used batteries to the battery distributors or the collection points of the municipal recycling centers / mobile hazardous waste collection points.
Why are batteries not allowed to be thrown away in household waste?
Batteries are often damaged in waste compactors and ignite explosively. There are no statistics on how often this happens. The industry assumes a double-digit number of fires per day
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