EU Battery Regulation in Germany: National Law, Producer Register, Authority and Penalties

The status is given as of 13 November 2026.

Regulation (EU) 2023/1542 applies directly in Germany and needs no transposition. The EU Battery Regulation sets the product and EPR duties; the BattDG decides who enforces them in Germany and how, with national rules on registration, take-back, authorities and penalties.

The five key points for Germany are listed below.

• BattDG in force since 7 October 2025 (see the EU Battery Regulation timeline)
• Authorities: Umweltbundesamt, stiftung ear, BAFA
• Registration per brand and per battery category
• Authorised representative for producers without a German establishment
• Fines up to EUR 500,000 (due diligence) and EUR 100,000 (registration) under § 60(3) BattDG

Germany's National Battery Law: Status as of 13 November 2026

As of 13 November 2026, Regulation (EU) 2023/1542 applies directly in Germany and the BattDG has implemented its national parts since 7 October 2025, about seven weeks after Chapter VIII started to apply on 18 August 2025. Article 93 required member states to lay down their penalty rules by the same date, 18 August 2025.

The key dates below come from the Federal Law Gazette, the Bundesrat, EUR-Lex and the BattDG.

The BattDG: Title, Gazette Reference and Dates

The BattDG was signed on 30 September 2025 as Article 1 of the Batterierecht-EU-Anpassungsgesetz (Batt-EU-AnpG, Battery Law EU Adaptation Act) and published in BGBl. 2025 I Nr. 233 on 6 October 2025.

Its full title is Gesetz zur Durchführung der Verordnung (EU) 2023/1542 betreffend Batterien und Altbatterien, the act implementing the Regulation on batteries and waste batteries.

The CDU/CSU and SPD parliamentary groups introduced the bill as BT-Drs. 21/570 on 24 June 2025, and the Bundestag environment committee approved it on 10 September 2025. The Bundesrat passed it on 26 September 2025 without calling the mediation committee (BR-Drs. 475/25). The act has 64 sections in seven parts.

From the BattG to the BattDG: Transition Rules

The BattDG replaced the Batteriegesetz (BattG, Battery Act) of 25 June 2009 from 7 October 2025 (Article 10 and Article 11(1) Batt-EU-AnpG). No part of the BattG applies as of 13 November 2026, but its producer registrations continued for a short period under the BattDG categories.

Those registrations stayed valid until the end of 15 January 2026: vehicle batteries became starter (SLI) batteries, industrial batteries became LMT, industrial or EV batteries, and portable batteries stayed portable (§ 64(1) to (3)).

Without proof of membership in an OfH (Organisation für Herstellerverantwortung, producer responsibility organisation) by that date, they are deemed revoked retroactively from 1 January 2026 (§ 64(7)).

The 2025 Amendment and the End of the National Collection Quota

Article 2 of the Act of 25 November 2025 (BGBl. 2025 I Nr. 286) is the last amendment of the BattDG as of 13 November 2026.

It replaces § 13 BattDG with a version without the national collection quota of 50 % of portable batteries per OfH in § 13(1), keeps the calculation rules and deletes the matching fine in § 60(1) Nr. 5.

The EU collection targets for portable batteries apply in Germany directly, with or without a national quota: 63 % by 31 December 2027 and 73 % by 31 December 2030 (Article 59(3) of the Regulation). The LMT rates of Article 60(3) are set out with them under collection targets.

Which Authorities Enforce Battery Law in Germany?

The Umweltbundesamt (UBA, German Environment Agency) in Dessau is the competent authority for Chapter VIII of the Regulation and Part 2 of the BattDG (§ 30 BattDG), and § 37 BattDG lets it entrust registration and approval tasks to the stiftung elektro-altgeräte register (stiftung ear). The Commission's Article 54 list (last update 31 May 2026) names both bodies.

By decision of 7 October 2025, the Umweltbundesamt entrusted stiftung ear with producer registration, the approval of OfHs and the tasks of the Altbatteriekommission.

The Umweltbundesamt remains the objection and supervisory authority and handles the reporting duties. The Commission list describes stiftung ear as "national register and authority for authorisation on fulfilment of extended producer responsibility".

The Bundesanstalt für Arbeitsschutz und Arbeitsmedizin (BAuA, Federal Institute for Occupational Safety and Health) channels notifications under Articles 79 and 81 and acts as Bundesstelle für Chemikalien in Article 86 restriction procedures (§ 42 BattDG). The Länder (federal states) set up the notifying authority (§ 43) and run market surveillance under the Marktüberwachungsgesetz (§ 2(3)).

The Altbatteriekommission (waste battery commission, §§ 35 to 36 BattDG) has 12 honorary members, among them three for producers and retailers and three for OfHs (§ 36(1)). It held its constituent meeting on 29 July 2026, and its office sits at stiftung ear.

The six bodies of German battery law and their roles are compared below.

BAFA and Due Diligence Supervision in Germany

BAFA is the competent authority for the due diligence chapter, Chapter VII, of the Regulation (§ 52(1) BattDG), under the supervision of the federal environment ministry (§ 52(2)). It can request documents, restrict or ban batteries and order recalls (§ 53(3)), with a coercive fine of up to EUR 50,000 (§ 58).

Battery due diligence duties apply from 18 August 2027 under Article 48(1) as amended by Regulation (EU) 2025/1561.

BAFA supervises the EU rules on battery due diligence; BattDG fines for a missing policy or risk assessment apply only three months after an operator reaches the Article 47 threshold (§ 60(2) Nr. 14, 16, 18 to 20). BAFA reports yearly (§ 54(2)).

What Producers and Sellers Must Do in Germany

A producer that makes batteries available in Germany registers with stiftung ear before the first sale and joins an OfH for each battery category or fulfils its duties individually.

Registration precedes first making available (§ 5(1) BattDG; Article 55(2)), and OfH participation is mandatory (§ 7(1)), with OfH approvals effective from 1 January 2026 at the earliest (§ 64(9)).

Retailers take back waste batteries free of charge (§§ 14, 18) and display notices at least in German, with a DIN A4 picture sign at the entrance (§ 24). Distance sellers give the same information online or in the parcel, and instructions and safety information must be in German (§ 48).

Six national duties apply on top of the Regulation; five of them have a detail page that covers the duty in full.

German Registration and Take-Back Rules That Go Beyond the Regulation

Germany registers producers per brand and per battery category, and the producer or its authorised representative must register even where an OfH acts for it (§ 5(1) BattDG).

Article 55(6) of the Regulation lets a producer responsibility organisation handle registration unless the member state provides otherwise; the EU baseline is explained under producer registration in each EU member state.

Unregistered producers may not make batteries available in Germany. Retailers (Händler) may not sell their batteries, and fulfilment service providers (§ 3 Nr. 2 BattDG) may not store, pack, address or ship them (§ 4).

A retailer that intentionally or negligently supplies batteries of unregistered producers is itself treated as a producer (§ 3 Nr. 1).

A German registration is valid only in Germany. No BattDG provision obliges online marketplaces to check producer registration; for them, Article 62(6) of the Regulation applies together with Article 30 of Regulation (EU) 2022/2065, the Digital Services Act.

Producers Without an Establishment in Germany: The Authorised Representative Duty

Every producer without an establishment in Germany, including a producer established in another member state, must appoint one authorised representative for extended producer responsibility in writing and in German, who registers and acts in its own name (§ 40(2) BattDG). The representative receives one registration number per represented producer (§ 31(1)).

The German rule goes further than the Regulation. Article 56(3) requires an EPR authorised representative only from producers under Article 3(1), point (47)(d), which sell by distance contracts directly to end-users in a member state where they are not established. The EU role is explained under EPR authorised representative.

Registrations of producers not established in Germany did not continue from the BattG into the BattDG (§ 64(4) BattDG), so these producers register anew through a representative. The representative carries the producer's duties under Chapter VIII of the Regulation and Part 2 of the BattDG (§ 40(2), first sentence).

Need help with battery compliance in Germany? Where the German duties sit in the full programme is set out under how to comply with the EU Battery Regulation.

Fines and Penalties in Germany: The Three BattDG Tiers

§ 60(3) BattDG sets three fine ceilings: up to EUR 500,000 for due diligence offences and for breaching BAFA restriction, ban or recall orders, up to EUR 100,000 for registration, sales-ban, take-back and documentation offences, and up to EUR 10,000 for all other offences.

The Regulation sets no fine amount and leaves penalties to the member states (Article 93).

Selling while unregistered and failing to register each carry up to EUR 100,000 (§ 60(1) Nr. 1, § 60(2) Nr. 23). Not charging or not refunding the starter-battery deposit, a missing or late CE marking and inaccurate battery passport data each carry up to EUR 10,000. Other member states set their own national penalties.

The Umweltbundesamt prosecutes registration and take-back offences and BAFA prosecutes due diligence offences (§ 61(1) BattDG). § 61(1) assigns the deposit and notice offences to neither authority, and objects related to an offence may be confiscated (§ 62). The table lists the three ceilings with example offences and the fining authority.

Germany in the EU-Wide Comparison

Germany has a national battery implementing act in force as of 13 November 2026, and it adds rules that the Regulation leaves to member states or does not set: registration per brand, a mandatory OfH, a starter-battery deposit and its own fine tiers. Each applies only to batteries made available in Germany.

Registers, producer responsibility rules and fine levels differ from one member state to the next, because each member state keeps its own register under Article 55(2). The EU Battery Regulation by country overview compares national acts, registers and fines.

Related EU Rules for Sellers in Germany

Five related pages cover the EU rules behind the BattDG.

• battery EPR under the Regulation
• producers under the EU Battery Regulation
• online sellers, marketplaces and fulfilment service providers
• the five battery categories
• EU Battery Regulation in Austria

Pending Changes Affecting Germany

As of 13 November 2026, the Commission proposal COM(2025) 982, which would suspend the Article 56(3) EPR authorised-representative duty until 1 January 2035, is pending. After a partial first-reading vote on 20 October 2026, the European Parliament referred it back to committee for interinstitutional negotiations, and no agreement had been reached by 13 November 2026.

The Council's negotiating mandate, agreed by Coreper on 21 October 2026 (Council document ST 14765/26), removes batteries from the proposal and does not change Article 56(3). Until an amending act is published in the Official Journal, Article 56(3) of Regulation (EU) 2023/1542 applies unchanged.

Common Questions on the German Rules

Three questions come up most often from producers outside Germany.

Do EU producers need an authorised representative in Germany?

Yes. Every producer without an establishment in Germany needs one, including producers established in another member state (§ 40(2) BattDG). The appointment is written and in German, and each producer appoints only one representative, who registers in its own name.

What replaced the old BattG in Germany?

The BattDG replaced the BattG from 7 October 2025 (Articles 10 and 11(1) Batt-EU-AnpG). The BattG implemented Directive 2006/66/EC, the Batteries Directive that Article 95 of the Regulation repealed with effect from 18 August 2025; the change is explained under what replaced the Batteries Directive.

Is a German registration valid in other member states?

No. A registration with stiftung ear is valid only in Germany. Article 55(2) of the Regulation requires a producer to register in each member state where it first makes batteries available, so a producer selling in three member states holds three separate registrations.