What is Germany EPR Batteries

Germany's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — and implemented nationally through the Battery Act Implementation Law (BattDG — Batteriedurchführungsgesetz), which came into force on 11 September 2025, replacing the previous Battery Act (BattG2) of 2021. The BattDG defines national responsibilities, registration obligations, and enforcement mechanisms within the framework of the EU Battery Regulation. The competent authority responsible for battery producer registration and enforcement in Germany is stiftung ear (Stiftung Elektro-Altgeräte Register). Stiftung ear manages the ear-Portal — Germany's electronic registration and reporting system for batteries and electrical equipment. Registration with stiftung ear is a legal prerequisite for market access — no battery may be placed on the German market without a valid registration number. Battery EPR has been mandatory in Germany for approximately 20 years. The BattDG represents a significant tightening of obligations, most notably making the appointment of an authorised representative mandatory for all foreign producers from 18 August 2025, and requiring all producers to join a Producer Responsibility Organisation (OfH) by 15 January 2026.

Does This Apply to E-Commerce & Online Sales

Yes. The BattDG and EU Battery Regulation apply to all producers placing batteries on the German market, regardless of sales channel. Distance sellers and e-commerce operators selling batteries or battery-containing products directly to German consumers are explicitly captured as producers. From 18 August 2025, online marketplace operators are required to verify that sellers on their platforms hold valid German battery registrations (Batt-Reg.-Nr. DE). This obligation applies to all marketplaces, consistent with the existing verification requirements for packaging (from July 2022) and WEEE (from January 2023). Amazon, eBay, Zalando, Kaufland, and other major platforms actively enforce this requirement — sellers without a valid Batt-Reg.-Nr. DE face listing suspension. Distributors and intermediaries who knowingly or negligently offer batteries from unregistered or improperly registered manufacturers are also treated as producers under the BattDG.

Who is the "Producer" under Germany EPR?

Under the BattDG and Regulation (EU) 2023/1542, a producer is any company that, in the course of commercial activity, places batteries — whether standalone or incorporated into products — on the German market for the first time under their own name or trademark. This covers:

1. Manufacturers established in Germany who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Germany from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Germany for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Germany who sell batteries or battery-containing products directly to German consumers.
6. Distributors who knowingly or negligently offer batteries from unregistered manufacturers — these are treated as producers under German law.
7. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Each brand and battery type must be registered separately with stiftung ear. Data from previous registrations with the former Federal Environment Agency (UBA) is not automatically transferred.

Who Must Register for EPR Batteries in Germany

All producers placing batteries on the German market must register with stiftung ear through the ear-Portal before placing any battery on the market. Registration is a legal prerequisite for market access. From 18 August 2025, foreign companies (those without a German legal establishment) can no longer register directly with stiftung ear. Self-registration by foreign producers is no longer permitted. All foreign producers must appoint a German-established Authorised Representative (AR), who then submits the registration on their behalf. Upon successful registration, producers receive a battery registration number (Batt-Reg.-Nr. DE) — the proof of EPR registration required by online marketplaces and distributors. By 15 January 2026, all producers (existing and new) must additionally provide proof of membership in an approved Organisation for Producer Responsibility (OfH) for each battery category. Registrations that fail to meet this deadline are revoked.

Germany EPR Battery Registration Threshold

The BattDG does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the German market must register regardless of size or volume. The only exemption in the EU Battery Regulation concerns batteries used in military or space equipment, which are outside scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect registration and reporting obligations.

Batteries Covered (and Excluded)

From 18 August 2025, Germany adopted the five-category structure of Regulation (EU) 2023/1542, replacing the previous three-category system: Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Starting, Lighting and Ignition (SLI) batteries Automotive starter batteries used in motorised vehicles. Industrial batteries Batteries used in industrial applications, stationary energy storage, and other applications not covered by other categories. Includes e-bike batteries used in professional contexts and batteries exceeding 5 kg. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

All existing registrations must be updated to the new five-category system by 15 January 2026. Registrations not updated by this deadline are revoked.

Producer Responsibility Organization (PRO)

From 18 August 2025, all battery producers in Germany — regardless of battery category or whether they previously had an individual take-back system — must join an approved Organisation for Producer Responsibility (OfH). The deadline for providing proof of OfH membership in the ear-Portal is 15 January 2026. The approved OfH for portable batteries is Landbell-OfH, formally approved by stiftung ear in December 2025. Landbell Group (operating through DS Entsorgung, ERP Germany, and Landbell Germany) offers OfH membership for portable batteries and industrial batteries. Other approved take-back systems and OfHs for specific categories are listed in the stiftung ear directory. For non-portable battery categories (SLI, LMT, EV), producers should check current approved OfHs directly with stiftung ear. The OfH is responsible for the nationwide take-back and disposal of waste batteries on behalf of its members. Without OfH membership, registration with stiftung ear will be revoked.

EPR Registration in Germany

The registration process for battery producers in Germany is as follows:

1. Determine whether your business qualifies as a producer under the BattDG and EU Battery Regulation — i.e. whether you are placing batteries on the German market under your own name.
2. If established outside Germany, appoint a German-established Authorised Representative (AR) before initiating any registration. Self-registration by foreign producers is no longer permitted from 18 August 2025.
3. The AR submits a registration application through the ear-Portal for each brand and battery category, providing company details, battery chemistry, the OfH, and the tax identification number of the producer.
4. Receive the battery registration number (Batt-Reg.-Nr. DE) — issued by stiftung ear after successful registration.
5. Join an approved OfH for each battery category and provide proof of membership in the ear-Portal by 15 January 2026.
6. Provide the Batt-Reg.-Nr. DE to online marketplaces (Amazon, eBay, Zalando, Kaufland etc.) and display it in the imprint of the German website.
7. Report battery volumes placed on the German market annually through the ear-Portal.
8. Retain records for audit by stiftung ear.

Processing time for registration at stiftung ear is typically 8–10 weeks, though this can be longer. Producers should allow sufficient lead time before launching battery product sales in Germany.

Authorized Representative

From 18 August 2025, the appointment of a German-established Authorised Representative is mandatory for all foreign companies placing batteries on the German market. Self-registration by foreign producers is no longer permitted — existing foreign registrations were cancelled automatically on 18 August 2025. The AR assumes all legal EPR obligations under the BattDG on behalf of the foreign producer. Core AR responsibilities include registration with stiftung ear, OfH membership administration, annual quantity reporting, and communication with stiftung ear. The Batt-Reg.-Nr. DE is issued to the AR, who forwards it to the producer. The AR must be established in Germany and is typically a compliance service provider specialising in EPR. Landbell Group, ecosistant, EARN, and Interzero EPR Services are among the providers offering AR services for German battery EPR. The AR appointment must be documented in a signed agreement including company details, a business licence extract, and a countersigned contract. The agreement is submitted to stiftung ear as part of the registration process.

What Data Must Be Reported

Producers must report the following data to stiftung ear annually through the ear-Portal (or via the AR):

• Total weight (kilograms) of batteries placed on the German market during the reporting year, broken down by the five battery categories and by battery chemistry type
• Brand names under which batteries were placed on the market
• OfH membership details for each battery category
• Collection and recycling performance data, reported through the OfH on behalf of members
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

Annual reporting for batteries is submitted once per year. Separately, WEEE reporting to stiftung ear is required monthly — battery reporting and WEEE reporting are independent obligations even for the same product.

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been mandatory in Germany for approximately 20 years. The BattDG and new registration requirements took effect from 18 August 2025. Key dates:

• 18 August 2025: BattDG obligations take effect. Foreign producer self-registration cancelled. AR appointment mandatory. New five-category system applies to all new registrations.
• 11 September 2025: BattDG formally replaces BattG2.
• 15 January 2026: Deadline for all existing producers to update registrations to the new five-category system, provide battery chemistry information, and submit proof of OfH membership. Registrations not updated by this date are revoked.
• Annual: Quantity reporting of batteries placed on the German market — timing set by stiftung ear, typically Q1 of the following year.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. Batt-Reg.-Nr. DE display The battery registration number must appear in the imprint (Impressum) of the German website. This is a German-specific requirement under the BattDG. Language requirements Consumer-facing information on batteries sold in Germany must be provided in German. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Germany.

EPR Eco Fees & Eco-Modulation

Germany's battery eco-contribution structure is administered through the approved OfH. Fees are based on:

• Weight (kilograms) of batteries placed on the market by category
• Battery chemistry — different chemistries carry different recycling costs
• Collection and recycling costs — the OfH calculates contributions based on the actual cost of the take-back, transport, and treatment system

Administrative fees payable directly to stiftung ear cover registration and reporting services. These are separate from OfH contributions. Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required. Germany's specific eco-modulation framework under the BattDG has not been published in full detail as of May 2026. Specific fee schedules should be confirmed with the chosen OfH at the time of membership registration.

Risks, Penalties & Common Mistakes

1. Operating without registration. Placing batteries on the German market without a valid Batt-Reg.-Nr. DE is a breach of the BattDG. Stiftung ear can issue fines of up to €100,000 and sales bans. Amazon, eBay, Zalando, and Kaufland will block listings without a valid registration number.
2. Foreign producers attempting self-registration after 18 August 2025. Self-registration by foreign producers is no longer permitted. Existing foreign registrations were cancelled automatically. Foreign producers must appoint an AR.
3. Missing the 15 January 2026 update deadline. All existing producers must update registrations to the new five-category system, provide chemistry information, and submit OfH membership proof by 15 January 2026. Non-updated registrations are revoked without further warning.
4. Not joining an OfH. OfH membership is mandatory for all battery categories from 18 August 2025 — individual take-back systems are no longer sufficient for portable batteries from 2026. Registration without OfH proof is revoked.
5. Treating battery and WEEE registration as the same obligation. Battery registration and WEEE registration are completely separate obligations with separate registration numbers. A WEEE registration number does not cover batteries and vice versa.
6. Missing the Batt-Reg.-Nr. DE display in the website imprint. The registration number must appear in the German website imprint. Its absence is independently actionable.
7. Underestimating processing time. Stiftung ear processing typically takes 8–10 weeks. Producers should not wait until immediately before launch to initiate registration.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries — standalone or incorporated into devices — and whether they are being sold to German consumers.
2. Appoint a German-established Authorised Representative immediately — self-registration for foreign producers is no longer permitted.
3. Have your AR submit a registration application through the ear-Portal for each brand and battery category, including chemistry information and OfH details.
4. Join an approved OfH — Landbell-OfH for portable batteries — and provide proof of membership in the ear-Portal by 15 January 2026.
5. Receive your Batt-Reg.-Nr. DE and provide it to Amazon, eBay, Zalando, Kaufland, and other marketplaces where you sell battery-containing products in Germany.
6. Display the Batt-Reg.-Nr. DE in the imprint of your German website.
7. Submit annual quantity reports through the ear-Portal or via your AR.
8. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and German-language consumer instructions.
9. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

Is battery EPR mandatory in Germany?

• Yes. Battery EPR has been mandatory in Germany for approximately 20 years. From 18 August 2025, the new BattDG (Battery Act Implementation Law) and EU Battery Regulation (2023/1542) apply in full. All producers must register with stiftung ear, join an approved OfH, and report annual volumes. Registration is a legal prerequisite — no battery may be sold in Germany without a valid Batt-Reg.-Nr. DE.

Can foreign brands register directly with stiftung ear?

• No. From 18 August 2025, self-registration by foreign producers is no longer permitted. All foreign companies must appoint a German-established Authorised Representative to submit and manage their registration. Existing foreign registrations were cancelled automatically on 18 August 2025. Companies that have not yet appointed an AR are in breach of the BattDG.

What is the deadline for joining an OfH?

• All producers must provide proof of membership in an approved Organisation for Producer Responsibility (OfH) in the ear-Portal by 15 January 2026. Registrations without OfH proof will be revoked. For portable batteries, Landbell-OfH was approved in December 2025. Producers in other battery categories should confirm current approved OfHs directly with stiftung ear.

How long does registration take?

• Processing at stiftung ear typically takes 8–10 weeks, and can take longer in high-demand periods. Producers should allow at least 8–10 weeks before their intended market launch date. Registration cannot be backdated — batteries placed on the market without a valid registration number violate the BattDG.

Is there a minimum volume threshold below which registration is not required?

• No. The BattDG does not establish a minimum volume or turnover exemption. All producers placing batteries on the German market must register and comply regardless of size. Each brand and battery type must be registered separately.

Textile EPR law in Germany: None enacted

Germany is not among the countries with enacted textile EPR legislation.