BattG battery registration in Germany for non-EU sellers (now BattDG)

If you searched for BattG: that act is gone. The Batterierecht-Durchführungsgesetz (BattDG) replaced the Batteriegesetz of 25 June 2009 on 7 October 2025. A seller outside Germany that supplies batteries to German buyers, loose or built into a product, appoints one German representative, joins a producer responsibility organisation (OfH) and registers each brand and battery category before the first battery is made available. This page lists only what Germany adds to the EU Battery Regulation, which says when you are the producer and what the rest of the Regulation requires. The other German rules are on the Germany hub.

BattG is now BattDG

The BattDG was issued on 30 September 2025 and entered into force on 7 October 2025. The official text states that it replaces the BattG. Its purpose is to carry out Regulation (EU) 2023/1542Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office. in Germany. stiftung ear still heads its English battery guide with the old name, but the guide applies the new law.

A BattG registration in the name of a business outside Germany ended with the old law (§64(4) BattDG). One held by your German representative carried over only if the proof of an OfH, and of the written mandate, reached the authority by 15 January 2026 (§64(7), (8)). Without that proof it counts as cancelled from 1 January 2026, and you apply again under the BattDG. stiftung ear says that most registrations could stay (press release, 16 January 2026).

Who registers, and where

The Umweltbundesamt is the competent authority. The law lets it entrust the joint body of the ElektroG with the registration tasks (§37(1)), and that body is stiftung ear. You apply in its ear-Portal, and stiftung ear issues the registration order with your registration number, Batt-Reg.-Nr. DE (stiftung ear).

You cannot register yourself without a German establishment. The producer mandates one representative in Germany, and the representative registers in its own name (§40(2) BattDG). Each represented producer gets its own registration number (§31(1)).

What a seller outside Germany does

1. Sign a mandate in German. One representative only, and the mandate is written and in German (§40(2)). The representative must be established in Germany (stiftung ear). The representative confirms the mandate in the ear-Portal with a qualified electronic signature and uploads a commercial register extract of the producer. For batteries, stiftung ear does not have to confirm the appointment, which is different from WEEE (stiftung ear). The EU side of this is in the EPR authorised representative.
2. Sort each battery into one of five categories. The categories are portable, light means of transport (LV), starter, industrial and electric vehicle batteries (stiftung ear). A portable battery is a sealed battery of 5 kg or less that is not designed for industrial use and is not a light means of transport (LV), starter or electric vehicle battery. An e-bike or e-scooter battery of up to 25 kg is an LV battery, even if it weighs under 5 kg. A battery built into a product counts too (Art. 55(2) of Regulation 2023/1542, stiftung ear).
3. Join an approved OfH for each category. The law requires a producer to take part in an OfH for each category or to run its own approved take-back (§7(1)), and registration is granted only on that basis (§31(1)). The approved OfHs are in stiftung ear’s directory. Each OfH gives you an OfH number to enter in the application and confirms your participation.
4. Apply for each brand and category. One registration for every brand and every category you supply, with the chemical composition of the batteries. A second brand is a second registration (stiftung ear).
5. Wait for the registration order before you list or ship. stiftung ear says that in online retail even offering batteries counts as making them available. The law also treats the registration as granted twelve weeks after all information is in, and you can ask for a written certificate with the number (§5(1)).
6. Update your quantities every year. You tell the OfH the mass supplied in each of the three previous calendar years, and you and the OfH report the figures to the authority together (§7(2)).

Keep the registration number. Marketplaces ask for it, as the EU guide explains. stiftung ear’s guidance says to state it when you offer batteries and on invoices. The BattDG text itself sets no such rule.

What it costs

The amounts are net. Value added tax is added where it applies (§1(1) ElektroGBattDGGebV). For one portable-battery brand the authority’s fees are EUR 16.40 once and EUR 15.20 a year.

Your reseller and your warehouse are affected too

A distributor may not make the batteries of an unregistered producer available. A fulfilment service provider may not store, pack, address or ship them. The law counts a fulfilment provider as anyone who offers at least two of those services for goods it does not own, and a courier or postal service does not count (§3, §4(3) BattDG). A distributor that knowingly or negligently supplies batteries of an unregistered producer is treated as the producer (§3 no. 1). So a German reseller or a German warehouse can stop your batteries before the authority does.

The fine for not registering

Making a battery available without proper registration carries a fine of up to EUR 100,000, and so does not registering in time. That covers a distributor that supplies the batteries of an unregistered producer. A fulfilment provider is barred from handling them, but the fine provision for fulfilment providers cites a §4(3) no. 3 that the published text does not contain, so this page does not state a fine for them. Most other breaches, such as instructions and safety information not in German, carry a fine of up to EUR 10,000 (§60 BattDG, §48). The Umweltbundesamt is the fining authority for the registration breaches (§61). If you do nothing, you may not make batteries available in Germany, and any German distributor or fulfilment provider has to stop handling them.