German battery law: What changed in 2025 – and what companies need to do in 2026
Battery compliance 2025: Key changes and developments at a glance
2025 was a key transition year for battery compliance in Germany. As part of the alignment with the EU Battery Regulation, registrations with stiftung ear were restructured, additional mandatory information was introduced, and the new Battery Implementation Act (BattDG) was adopted. For manufacturers, importers and distributors, this mainly meant: new categories, new evidence requirements and a significantly higher documentation effort.
New battery registration: Five categories and more mandatory information
Battery registration was expanded in terms of content and technically revised in 2025. Going forward, five battery categories instead of three will apply. At the same time, new mandatory information in the ear portal became required, in particular:
chemical composition
tax identification number
designation of a Producer Responsibility Organisation (PRO)
This makes registration significantly more detailed – and errors or missing information may lead to withdrawals more quickly in the future.
Transition periods and changes to evidence requirements
For existing registrations, it was stipulated that missing information must be added by 15 January 2026 at the latest in order to maintain the registration. In addition, registrations had to be submitted under the new system from the August 2025 cut-off date onwards.
For portable batteries, a limited transition rule still applied: evidence of an individual take-back scheme could be submitted until the end of 2025. For all other categories, return options could continue to be recorded in the ear portal.
Foreign manufacturers: Registration only possible with an authorised representative
A significant tightening affected foreign manufacturers: direct registration without a representative is no longer possible. Instead, an authorised representative based in Germany is mandatory. Existing registrations without an authorised representative were revoked accordingly.
BattDG: New German battery law enters into force
In 2025, the Battery Implementation Act (BattDG) was also adopted and entered into force. It replaces the previous Battery Act (BattG) and implements the EU Battery Regulation at national level. Particularly relevant aspects include:
an expanded definition of “manufacturer” (distributors may, under certain circumstances, be considered manufacturers themselves),
the option to fulfil take-back obligations collectively via a PRO (or alternatively on an individual basis),
a national collection rate of 50% for waste portable batteries,
the introduction of a Waste Battery Commission as a new advisory body.
Status quo 2026: What applies now?
15 January 2026: Deadline for existing registrations has passed
By 15 January 2026, existing battery registrations with stiftung ear had to be supplemented with additional information, including the designation of a PRO.
Those who did not comply by the deadline had to expect the withdrawal of their registration – with significant consequences for their ability to place products on the market.
More PROs approved – but the pressure to act remains
After an initial shortage of approved PROs (especially for portable batteries), further organisations were approved at the end of 2025 and in early 2026. This has generally improved the range of available options – however, the obligation remains unchanged: for each relevant battery category, valid evidence must be provided and confirmed.
Consequences of missing the deadline: Market ban and re-registration
Companies whose registration has been withdrawn are currently not allowed to offer or place batteries on the market in Germany, as a valid registration is a mandatory prerequisite.
Re-registration is possible, but results in:
additional registration fees
effort required for evidence and confirmations
delays due to processing times
What to do now: The most important steps for 2026
1) Check registration status (immediately)
Is the battery registration active and valid?
Has all mandatory information been provided (chemistry, tax ID, category)?
Has the PRO been correctly designated and confirmed for each category?
2) Correctly assign battery categories
Since five categories have applied since 2025, correct classification is crucial – both for registration and for evidence requirements and fee models.
3) Ensure PRO contracts for each category
The rule for each category is: without participation in a PRO (or an individual compliance solution), the registration is not robust.
4) Foreign manufacturers: Observe the authorised representative requirement
Without an authorised representative based in Germany, foreign manufacturers cannot maintain an effective registration or register properly.
Due to the expanded definition of “manufacturer”, the risk for distributors increases: anyone placing batteries on the market from manufacturers that are not correctly registered may be considered a manufacturer themselves. Supply chains and evidence should therefore be reviewed consistently.
