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The provisions of the EU Battery Regulation (Regulation (EU) 2023/1542), which entered into force in August 2023, have largely been applicable in the Member States since 18 August 2025. This created a need to adapt legislation at national level, a requirement that was met by the act adapting national legislation on batteries to the EU Battery Regulation (Regulation (EU) 2023/1542) – the Battery Law EU Adaptation Act. The cornerstone of this is the new Battery Implementation Act (BattDG), which replaces the previous Batteries Act (BattG) that focussed heavily on the return and disposal of waste portable batteries.
The new provisions lay the foundation for effective enforcement of the provisions of the EU Battery Regulation and the Act. The Act provides important clarifications and supplementary provisions to ensure that the targets of separate collection and high-quality recovery can be achieved, in particular at the end of the life cycle of batteries. Producers of all types of batteries will be now be responsible for the entire life cycle of their products.
What’s new?
Waste battery collection: consumers are obliged to return waste batteries to retailers or other collection points for waste batteries. Return is free of charge.
Retailers and municipal collection points (for example civic amenity sites) are required to take back free of charge waste portable batteries and waste light means of transport batteries (LMT batteries), such as those used in e-bikes and e-scooters. In addition, other facilities and companies may voluntarily take back waste portable batteries or LMT batteries. Waste batteries taken back by retailers, municipal or voluntary collection points are passed on to a producer responsibility organisation. These organisations are responsible for the proper disposal of the collected waste batteries on behalf of producers.
Retailers are also responsible for starting, lighting and ignition batteries (SLI batteries) and industrial and electric vehicle batteries: these waste batteries can also be returned to retailers free of charge. Municipal collection points can also take back SLI batteries and industrial batteries.
Ambitious collection rates for waste portable batteries: in Germany, the current collection rate for waste portable batteries is 50 percent. This rate is higher than the rate set out in the EU Battery Regulation. To further improve collection, the Battery Implementation Act retains the higher German collection rate until the end of 2026 and then aligns with the ambitious rates specified in the EU Battery Regulation.
- 50 percent today
- 63 percent from 2027
- 73 percent from 2030
The compulsory deposit on SLI batteries from vehicles has been retained as this has proven successful in the past. Distributors of automotive batteries (SLI batteries for vehicles) are thus still required to charge end consumers a deposit of 7.50 euros including VAT if they do not return a used automotive battery when purchasing a new one. The deposit is reimbursed when an automotive battery is returned. Distributors offering automotive batteries remotely or online (distance selling) have the option to reimburse the deposit upon receiving proof of return instead of the actual used battery. The proof of return documents the proper disposal of the battery, for example by a public waste management authority or a local retailer. Distributors offering batteries of the same type are obligated to take back waste automotive batteries free of charge and provide consumers with proof of return. Waste automotive batteries that are returned can be disposed of by the distributors themselves or handed over to producers free of charge for disposal. Distributors who place industrial batteries on the market are obliged to take back used batteries of the same type free of charge. Distributors can dispose of the batteries themselves or return them to the producers free of charge.
Waste Battery Commission: a Commission comprising representatives of producers, producer responsibility organisations, municipalities, municipal and private waste management companies and environmental and consumer protection associations, will in future advise the competent authority on technical and waste-related matters.
Definition of responsibilities and powers: national authorities have been designated as the competent authorities for the regulatory areas including: management of waste batteries, substance restrictions, conformity of batteries and due diligence requirements in the supply chain.
In the area of waste management, the previous requirements set out in the Batteries Act continue to apply. The German Environment Agency (UBA) is, in principle, the competent authority in this area. However, it may transfer tasks by designating responsibilities to "stiftung elektro-altgeräte register" (stiftung ear), the authority under the Electrical and Electronic Equipment Act for registering producers. Since UBA decided to exercise this option, stiftung ear thus remains responsible for registering producers and approving producer responsibility organisations.
The federal states (Länder) are required to establish a competent authority for the area of conformity. These authorities are responsible for notifying conformity assessment bodies. The German Accreditation Body (DAkkS) assesses and monitors the conformity assessment bodies.
The Federal Office for Economic Affairs and Export Control is responsible for the supervision of due diligence requirements.
Implementation provisions for the management of waste batteries: specific authorisation requirements are laid down for producer responsibility organisations or producers who individually exercise their extended producer responsibility, as well as specific rules on how to deal with collected waste batteries.
Penalties for infringements: a comprehensive list of fines is intended to penalise infringements of the obligations set out in the EU Battery Regulation and the Battery Implementation Act (BattDG) and thus sanction improper conduct.