Germany EPR

Batteries (BattG) Packaging (VerpackG) Electrical and Electronic Equipment - WEEE (ElektroG)

The Complete Guide to EPR for Batteries in Germany (BattG & BattDG)

If you manufacture, import, or sell batteries (or products containing batteries) in the German market, complying with Extended Producer Responsibility (EPR) regulations is not optional—it is a legal requirement.

With the shift from the traditional Battery Act (BattG) to the new Battery Implementation Act (BattDG) under the updated EU Battery Regulation, the compliance landscape has become more complex. This guide explains everything you need to know about German battery law to stay compliant.

1. Introduction to EPR in Germany

Extended Producer Responsibility (EPR) extends a producer's responsibility to the post-consumer stage of a product's lifecycle. In Germany, this applies to packaging, electronics, and batteries.

For batteries, EPR ensures that producers are responsible for collection, recycling, and environmentally safe disposal, supporting a circular economy and reducing hazardous waste.

2. Legal Framework and Regulations in Germany

The battery compliance framework is currently transitioning:

BattG (Battery Act): Earlier national implementation of EU Battery Directive
EU Battery Regulation (EU 2023/1542): New harmonized EU framework
BattDG (Battery Implementation Act): German implementation replacing BattG

From 2026, all producers must participate in an approved Producer Responsibility Organization (PRO / OfH), alongside other obligations under Germany's product safety law (EU GPSR).

3. Who Must Register for EPR Batteries in Germany ?

You are considered a "producer" if you place batteries on the German market. This includes:

Manufacturers producing batteries in Germany
Importers bringing batteries into Germany, often via an Importer of Record service for Amazon FBA Germany
E-commerce sellers and dropshippers shipping to German consumers
Resellers distributing unregistered batteries

4. EPR Categories for Batteries

Germany classifies batteries into five categories:

Portable Batteries (≤5 kg)
Industrial Batteries (>5 kg or industrial use)
SLI Batteries (vehicle ignition and lighting)
LMT Batteries (≤25 kg, e-bikes, e-scooters)
EV Batteries (electric and hybrid vehicle traction)

Sellers who also handle electronics should review our related guidance on WEEE registration for German electronics sellers.

5. Registration Process (Stiftung EAR)

Before selling, you must obtain a Batt-Reg.-Nr. DE via Stiftung EAR.

Create an EAR account
Classify battery type and brand
Declare chemical composition
Provide proof of PRO participation
Receive registration approval

6. Authorized Representative

Foreign companies must appoint a Germany-based Authorized Representative who assumes legal responsibility for compliance and communication with authorities.

7. Reporting Obligations

Periodic reporting (monthly, quarterly, or annual depending on PRO)
Annual declaration of total weight placed on market
Strict audit trail requirements for compliance verification

8. EPR Fees and Eco-Contributions

Administrative registration fees paid to Stiftung EAR
PRO eco-contributions based on battery chemistry and weight
Costs funding national collection and recycling systems

For a full breakdown of service costs related to compliance registrations, see our pricing page.

9. Labeling Requirements

Crossed-out wheeled bin symbol (mandatory)
Chemical symbols (Hg, Cd, Pb where applicable)
QR code "Battery Passport" requirement starting 2027 for selected batteries

These labeling rules complement other German compliance obligations such as those under the German single-use plastics law.

10. Penalties for Non-Compliance

Fines up to €100,000 per violation
Marketplace bans (Amazon, eBay, Etsy)
Sales prohibition orders
Confiscation of profits from non-compliant sales

Given the complexity of battery compliance in Germany, many sellers—including those managing EPR for Amazon sellers in Germany—choose to work with a dedicated compliance partner to avoid registration errors and missed deadlines. If you need help identifying the correct PRO, registering your products, or managing annual declarations, contact our compliance team for tailored support.