Choosing a qualified authorized representative (AR) is the most important decision international companies can make to comply with the German Battery Act (BattG). An experienced partner not only ensures your BattG registration with the EAR Foundation, but also protects you from fines and sales bans.
Legal basis:
According to the German Battery Act (BattG), an authorized representative is your legal representative in Germany. This is mandatory for every manufacturer who does not have their own branch in the country. This officially appointed person or organization acts on your behalf and assumes full responsibility for compliance with all BattG regulations. They are your authorized contact person for all official inquiries.
According to Section 26 of the BattG, an authorized representative is a legal or natural person in Germany who is appointed by a foreign manufacturer.
Your duties as a legal representative:
- Act on behalf of the foreign manufacturer.
- Assume full legal responsibility for compliance with the BattG regulations.
- Serve as the official contact person for the EAR Foundation and German authorities.
Obligation for foreign manufacturers: Anyone who places batteries on the market in Germany but does not have a branch in the country must appoint an authorized representative. Without this representative, registration and thus sales are not legally permissible.
Selection criteria: How to find the right partner
Recognition and experience
Check whether the service provider has been listed with the EAR Foundation for many years. In-depth knowledge of the current EU Battery Directive and the German BattG is essential.
Speed and deadline management
Compliance deadlines are strict. Your partner must respond quickly to quantity reports, document checks, and requests from authorities in order to avoid penalties.
Full-Service offerings
A professional partner such as ECOPV-EU GmbH offers more than just a signature:
- Validation of reporting data: Correct quantity reports (monthly/annually).
- Document management: Legally compliant archiving of all evidence.
- Organization of battery take-back: Cooperation with approved take-back systems (OfH).
Caution: Warning signs when choosing a service provider
Avoid providers that exhibit the following characteristics:
- Opaque pricing structure: Be wary of hidden costs for new SKUs or master data changes.
- Communication barriers: Slow responses significantly increase your liability risk.
- Lack of expertise: A pure address service provider without EPR expertise is not sufficient for complex BattG compliance.
By commissioning a specialized partner, you benefit from:
- Accelerated EAR registration: We know exactly what documents the authorities require.
- Risk minimization: We act as your legal shield against German enforcement measures.
- Market access: We guarantee the smooth and permanent sale of your products in Germany.
FAQ: Frequently asked questions
Do small online retailers also need an authorized representative?
Yes. As soon as you are based outside Germany and sell batteries (including those in devices) to German end customers, the obligation to have an authorized representative applies.
Does Amazon or eBay assume the role of authorized representative?
No. Marketplaces only check your registration number (EPR number). You must cover the legal role of the authorized representative through an external specialist such as ECOPV.
Does the registration remain valid if the authorized representative changes?
A change is possible, but requires coordinated deregistration and re-registration with the EAR Foundation in order to avoid a gap in compliance.
Start your BattG compliance in Germany now
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