News on the BattG

As part of the new EU Battery Regulation, the new Battery Law Implementation Act (BattDG) will replace the existing Battery Act (BattG). All battery manufacturers must participate in a producer responsibility organisation, and producer responsibility will be introduced for all battery categories. Additionally, system operators must provide an insolvency-proof guarantee.
On 10 May 2024, the Federal Ministry for the Environment published a draft bill to adapt to the new EU Battery Regulation. The EU Battery Regulation (EU-BattVO) replaces the EU Battery Directive and has been directly applicable in Germany since 18 February 2024. The core of the draft is the new Battery Law Implementation Act (BattDG), which is set to replace the existing Battery Act (BattG) on 18 August 2025.
Here are some of the key impacts of the BattDG:
The aim of the draft bill to adapt battery law to the Regulation (EU) is to create a unified legal framework. This includes requirements for the production and disposal of batteries, regulations on substance restrictions, design, labelling, conformity, and due diligence, as well as the collection and treatment of waste batteries.
The new legislation adopts essential regulations from the previous BattG and primarily affects the producer responsibility for batteries. Thus, all battery manufacturers must participate in a producer responsibility organisation. The collective responsibility of producers will be introduced for all battery categories, including industrial batteries. The obligations of each manufacturer will be extended to waste batteries for various vehicles such as light means of transport, starter, industrial, and electric vehicle waste batteries.
Furthermore, a significant increase in the approved take-back systems is expected, from the current 9 approved own take-back systems to approximately 75, or around 15 per category. A new obligation for system operators to provide insolvency-proof guarantees in the event of a system’s withdrawal is introduced. This security serves to finance the later disposal of long-life waste batteries. Regular review and adjustment of the security is planned, especially with increasing quantities placed on the market by the battery manufacturers connected to the respective system. In case of non-compliance with legal requirements, such as failing to meet legal collection targets or not following orders to increase the security, there is the possibility of revocation of the approval.
The collection targets for various battery categories will be adjusted to EU requirements. For portable batteries, 63 percent by the end of 2027 and 73 percent by the end of 2030; for light means of transport (e.g. electric bicycles or e-scooters), 51 percent by the end of 2028 and 61 percent by the end of 2031. The BattDG sets a higher collection rate for portable batteries in Germany at 50 percent (EU 45 percent).

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