As previously reported in our newsletters, the currently applicable Battery law (BattG) in Germany will be replaced by the new Battery Law (BattDG) on August 18, 2025. The German Ministry for the Environment (BMUV) released a draft of the new BattDG in early May 2024.
The main points of the new law are as follows:
- Stiftung EAR remains the battery register: The German authority Stiftung EAR will continue to act as a control authority responsible for managing the manufacturer register as well as overseeing and verifying EPR compliance for manufacturers and producer organizations. This arrangement is expected to continue uninterrupted and possibly be expanded beyond August 2025. It is currently unclear whether amendment requests will be required for manufacturers of certain battery categories.
- Name change from battery type to battery category: The current classification into three battery types (portable battery, industrial battery, vehicle battery) will be redefined into five battery categories (device battery, LV battery, starter battery, industrial battery, and electric vehicle battery). Within these categories, there will be further subcategories, which have not yet been precisely defined.
- Special tariffs for “environmentally friendly” batteries: All EPR battery collection systems in Germany will be required to offer special recycling tariffs that account for the sustainable and ecological design of new batteries. This includes batteries with low hazardous material content, low carbon footprint, high longevity, good reusability or recyclability, high recycled content, etc.
- Collection of all battery types through approved EPR systems: In the future, all battery categories (including industrial, LV, electric vehicle, and starter batteries) must be collected and recycled through an approved, nationwide collection system. All used batteries should be able to be returned and disposed of free of charge by owners.
- Approval of EPR battery collection systems: There will be a new approval process for all battery take back systems. For the first time, a financial security deposit (financial guarantee) will be required.
- Responsible authorities: The draft of the new BattG in Germany aims to clarify the responsibilities of the various authorities under the EU Battery Regulation (EU-BattV). There will be three areas of responsibility:
- Registration/Extended Producer Responsibility (EPR): This task will continue to be managed by the EAR Foundation (as the authority commissioned by the Federal Environment Agency (UBA)).
- Due diligence in the supply chain: The EU Battery Regulation introduced due diligence and reporting obligations for companies along the battery supply chain. In Germany, this task will be assigned to the Federal Institute for Geosciences and Natural Resources (BGR).
- Notifying authority for the authorization of conformity assessment bodies: Each federal state is expected to establish its own office. Further details are not yet known.
The central requirements for the various market participants (manufacturers, importers, distributors, etc.) are described in the EU Battery Regulation, which has been in effect since February 2024 in all 27 member states. Some of these obligations will only take effect after specific transition periods.
If you have any questions, you can contact the Go4Recycling team at any time.