Implementation of the EU Battery Regulation in Germany – additional information obligations

On 7th October 2025, the German implementation of the EU Battery regulation (BattDG) was published and came into effect. It replaces the previously applicable German battery law (BattG) and complements the EU Battery Regulation (EU-BattVO), which has been in force since 18 August 2025.

In our previous newsletters, we have already provided information on numerous changes. With this newsletter, we now focus on the new or updated information obligations for manufacturers, onlineshops, distributors, and points of sale that come into effect with the implementation of the EU Battery Regulation.

A central goal is to inform consumers about the collection, return, and recycling of batteries, as well as the associated costs. Of particular relevance are the information obligations under Article 74 of the Battery Regulation.

Article 74 of the EU-BattVO obliges distributors, points of sale, and in most cases also online retailers to comply with a series of specific information requirements, including:

  • Information on collection and return points
    Consumers/end users must be clearly and visibly informed about the possibility of returning used batteries free of charge.
  • Information on collection and recycling
    There is an obligation to explain the importance of separate collection of used batteries and the process of recycling.
  • Safety and environmental notices
    Consumers must be informed about the dangers of improper disposal and the contribution of recycling to environmental protection and resource conservation.
  • Cost information according to Article 74(5)
    Distributors and points of sale must also communicate the average costs borne by manufacturers for the collection, treatment, and recovery of used batteries. According to GRS, no distinction is made between battery categories, meaning this obligation applies to all batteries and all distributors/points of sale.

Average battery disposal costs at Batterie-zurück.de
“Batterie-zurück.de” is not a separate EPR take back system but a joint communication campaign by the official battery take-back systems operating in Germany. Its aim is to inform consumers in a uniform and visible way about the return and recycling of batteries and accumulators.

The average costs borne by manufacturers are published here:
Was kostet die Batterieentsorgung? |

Batterie-zurück.de also provides additional information materials, such as banners for POS and online shops. Please contact the email address provided on their website for requests.

Their website also offers valuable information on:

  • Resource conservation
  • Environmental protection
  • Safety assurance

The GRS take-back system additionally provides many other resources available for download:

Mediathek | GRS Batterien Service GmbH

According to GRS, the downloads and the texts they contain are freely available. Companies can adapt them to their individual local or online circumstances.

Information obligations for onlineshops and distance sellers

Detailed information on the new information obligations for online shops can be found on the website of our partner, IT-Recht Kanzlei:

Neue Online-Informationspflichten für Batterien – Umsetzungshilfen für Händler

The German WEEE authority Stiftung EAR (EAR) has also published an information brief on the implementation of the EU Battery Regulation, explaining the new legal situation:
ear INFObrief 4/2025

Finally, you can find the Battery Law EU Adjustment Act (Batt-EU-AnpG) here:
regelungstext.pdf

If you have any questions feel free to ask the Go4Recycling Team

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