Changes to battery registration in Germany starting 18 August 2025
As of 18 August 2025, significant amendments to battery registration regulations will take effect. Producers placing batteries on the German market must ensure compliance with the new requirements to maintain market access.
Key Changes at a Glance
Introduction of New Battery Categories: The current classification of three battery types will be replaced by five distinct battery categories.
Participation in a Producer Responsibility Organization (PRO):
Producers will have the option to fulfill their extended producer responsibility through membership in a recognized PRO.
Mandatory Information in the ear Portal: New registration applications must include details such as the chemical composition of batteries and the tax identification number of the producer.
Impact on Existing Registrations
Producers with existing registrations must update their entries by 15 January 2026, to include:
Chemical composition
Tax ID
Confirmation of participation in a PRO (or equivalent evidence of individual take-back solutions)
Failure to provide this information by the deadline will result in the revocation of the registration.
Registration Requirements – Timeline Overview
Until 18 August 2025:
Registrations can be submitted under the current legal framework.
For portable batteries, proof of an approved individual take-back system remains mandatory.
For electric vehicle and industrial batteries, return options must be specified in the ear portal.
From 18 August 2025:
All new registrations must align with the revised five-category system.
For portable batteries, documentation of individual take-back systems may still be submitted until 31 December 2025.
For all other categories, return options must continue to be documented via the ear portal.
Deadline: 15 January 2026
By this date, producers must:
Demonstrate participation in a Producer Responsibility Organization, or
Provide documentation of their individual compliance with extended producer responsibility obligations.
Registrations that fail to meet these requirements will be revoked. If the documentation is submitted on time, the registration will be granted retroactively from 1 January 2026.
Additional Rules for Foreign Producers
Foreign producers will no longer be permitted to register directly. Instead, they must appoint an authorized representative based in Germany to assume full responsibility for compliance with all obligations under extended producer responsibility legislation.
Important:
If no authorized representative is appointed by 18 August 2025, existing registrations will be revoked.
Recommendation:
To avoid market disruption, designate an authorized representative as early as possible.
