Duties according to the BattDG

The BattDG states that producer have certain obligations towards customer in terms of labelling and providing information:

Information obligations of producers

Under Article 74(1) of the Battery Regulation (BattVO), producers must provide retailers and end users with extensive information.  

  • Guidance on waste prevention and extending the service life of batteries 

  • Obligation for end users to collect used batteries and rechargeable batteries separately and to hand them in at a suitable collection point (e.g. in retail stores or at municipal recycling centres) 

  • Option of free-of-charge return to return or collection points 

  • Safety instructions for handling waste batteries 

  • Explanation of the markings and symbols under Article 13 (e.g. crossed-out wheeled bin) 

  • Information on environmental impacts 

Information obligations of retailers 

Retailers are also required to provide end users with comprehensive information (Article 74(4) BattVO): 

  • Passing on producer information: All guidance provided by the producer must be passed on to end users. 

  • Own notices: Retailers must also provide clearly visible information on return options – in-store and online. 

Separate disclosure of disposal costs 

A key new requirement: disposal costs must be shown separately when selling new batteries (Article 74(5) BattVO). While this was prohibited under the former German Battery Act (BattG), it is now mandatory. 

Battery Implementation Act (BattDG) 

In addition to the European Battery Regulation (BattVO), Germany will have a Battery Implementation Act (BattDG). This contains supplementary provisions that specify the European requirements. The Bundestag has already passed the act; the Bundesrat has not yet dealt with it. 

According to the current status, the following specifications are planned in particular for retailers: 

  • In brick-and-mortar retail, the information must be displayed in a clearly visible manner at the point of sale using signage or visual panels. 

  • In online retail, the information must be displayed prominently via digital image panels and be easy to find on the website, or be enclosed in writing with the shipment of goods. 

  • The information must be provided in German.