BattDG in Germany. What does this mean for manufacturers and distributors?

The new Battery Implementation Act (BattDG) will come into force on 18 August 2025. The Act focuses on official responsibilities, registration obligations, data reporting and sanctions – not on the product characteristics of the batteries themselves. Anyone who places batteries or battery-powered products on the German market should prepare for the new regulations in advance.

Who does the BattDG apply to?

The law applies to companies that do the following activities in Germany:

• place batteries or devices with built-in batteries on the German market,
• commercially distribute, import or export batteries,
• offer batteries or battery-powered devices as an online retailer or platform operator,
• provide storage, packaging or shipping services as a fulfilment service provider.

Manufacturers based outside Germany who supply directly to end users in Germany are also subject to the provisions of the BattDG.

Key obligations under the BattDG

1. Registration obligation

   In future, all manufacturers and importers must register with the Federal Office for Chemicals (BfC). Without registration, distribution in Germany is prohibited.

2. Data reporting and notification obligations

   Companies must regularly provide information to the relevant authority:
   • Quantities of batteries placed on the market,
   • Results of take-back and recycling,
   • changes in company data or product categories.

3. Verification and documentation

   Take-back systems and recycling processes must be verifiable and auditable.

4. Take-back obligations

   Suppliers must take back batteries free of charge. This applies to both the stationary and mail-order trade.

5. Labelling and information obligations

   End users must be informed, in a visible and comprehensible manner, that batteries can be returned free of charge after use and that they are legally obliged to return them. In addition, batteries must be labelled with the trash can symbol.

6. Obligations for online retailers and fulfilment service providers

These actors must ensure that a properly registered manufacturer is provided. Otherwise, they themselves may be liable.

New battery categories – with individual obligations

In the course of the new regulation, the battery types were reclassified. Different obligations apply to each category – in particular with regard to registration, take-back, labelling and CO₂ certificate:

1. Device batteries

   These are batteries for everyday use. In the future, they must be easily removable and clearly labelled.

2. Starter batteries

   These batteries are used in vehicles with combustion engines, e.g. for starting and lighting. They are subject to labelling requirements and will probably also be subject to traceability and CO₂ accounting requirements in the future.

3. Traction batteries

   These are batteries for powering electric vehicles – such as in electric cars or e-buses. The most extensive obligations apply here: registration, battery passport, take-back, durability certificate, CO₂ balance and labelling.

4. Industrial batteries

   These are used, for example, in solar systems, forklifts, UPS systems or stationary energy storage. They are also subject to registration and – depending on the type – battery passport and CO₂ documentation.

5. Batteries for light vehicles

   This newly introduced category includes batteries for e-bikes, e-scooters, hoverboards and similar vehicles. In addition to the general obligations, there are special requirements for charging cycles, durability, safety and labelling.

What sanctions are imposed for violations?

The BattDG provides for the following sanctions for violations:

• Fines of up to €100,000,
• Sales bans,
• Publication of violations,

Further administrative measures, such as take-back obligations.