Removal of Previous Information Obligations for E-Bike Batteries under the New BattDG

Under the former German Battery Act (BattG), which was replaced in August 2025 by the new Battery Implementation Act (BattDG) as part of the implementation of the EU Battery Regulation, manufacturers of industrial batteries were required to annually publish information on the achieved recycling rates for waste industrial batteries on their websites. In addition, distributors were subject to information obligations regarding the take-back and recycling of batteries.

These regulations have now been fundamentally revised and replaced through the introduction of the new EU Battery Regulation and the BattDG in Germany. In the future, reporting obligations will be handled centrally by the Producer Responsibility Organizations (OfH) towards the German Environment Agency (Umweltbundesamt).

Based on our current assessment — which is also shared by the OfH GRS — the previous obligation to publish this information in the legal notice (Imprint) or on the company website will no longer apply in its previous form.

An important reason for this change is the new classification of e-bike batteries. Under the former BattG, e-bike batteries were generally classified as industrial batteries. Under the new EU Battery Regulation and the BattDG, however, e-bike batteries are now classified as LV batteries (Light Means of Transport Batteries).

As a result, the previous publication and information obligations under the BattG are currently no longer foreseen for this category in the same form.

Upon request, we can provide our customers with the final recycling performance report for 2025 prepared under the former BattG framework. Please contact your Go4Recycling representative if you would like to receive a copy by email.

If you have any questions, the Go4Recycling team will be happy to assist you at any time.

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