BattDG in practice: PRO approval missing, deadlines running – what you can do now
There are currently numerous customer enquiries about how to implement the new Battery Implementation Act (BattDG) in practice.
What this is about
The new act entered into force on 7 October 2025 and thus replaces the previous Batteries Act (BattG).
Existing battery registrations with stiftung ear must be supplemented with additional information by 15 January 2026. That information must include, among other things, the designation of a so-called Producer Responsibility Organisation (PRO), which will replace the former take-back systems. If the additional details are not provided, the registration will be revoked by stiftung ear.
So far, only few PROs that are open to all producers have been approved. Several current take-back systems (potential future PROs) have expressed substantial criticism of the current interpretation and implementation of the BattDG. Their main concerns are the significantly increased requirements for financial guarantees for PROs and the very short implementation period.
Bitkom is actively working with other manufacturers’ associations to develop concrete solution proposals.
What you can do now
To speed up the upcoming allocation, please prepare the following additional information:
Tax number of the company registered with stiftung ear.
Battery categories – list according to the five categories: portable batteries, light means of transport batteries, industrial batteries, starter batteries and electric vehicle batteries.
Chemical composition / chemical system: assign each battery category to its chemical system (e.g. Li-ion, NiMH, lead, etc.).
Annual quantities (in kilograms): where applicable provide quantities for the last three calendar years, broken down by battery category.
Overview of which take-back solution you are currently using (own take-back solution or take-back system).
Support from Bitkom
We offer our customers free consultation hours in which our team presents current developments and answers questions.
If you require individual advice, please feel free to contact us. For example, we review your product range and support you throughout the process.
The legal situation remains very dynamic. We will continue to monitor developments closely and will inform you immediately if deadlines or requirements change or if a practical solution emerges.
