Risk of market disruption in Germany’s battery sector – Bitkom, VDMA and ZVEI demand moratorium
Bitkom, VDMA and ZVEI warn of regulatory gridlock in the German battery market. The three associations are calling on the Federal Ministry for the Environment to temporarily refrain from applying the provisions of the new Battery Implementation Act (BattDG) and to declare an immediate enforcement moratorium.
Under the BattDG, all manufacturers—both battery producers and manufacturers of devices with built-in batteries or rechargeable batteries—must update their battery registration with Stiftung ear (the German WEEE Register) by 15 January 2026 and designate an approved Organisation for Producer Responsibility (OfH). However, as of the current status (19 December 2025), the number of approved OfHs is insufficient to accommodate all manufacturers within a short timeframe. At present, there is only one certified OfH for the category of device batteries.
As a result, many companies will be unable to complete their registrations on time. From 16 January onward, hundreds of thousands of batteries could therefore no longer be placed on the market—for example for medical devices, forklifts and logistics vehicles, as well as numerous everyday products ranging from household appliances to consumer electronics. The consequences for supply chains and market availability of batteries and battery-powered products would be felt immediately. One reason for the current shortage of approved OfHs is, among other things, the high security deposits required as a prerequisite for approval.
Industry has a strong interest in implementing the BattDG in a legally compliant manner. However, as long as only a few OfHs are approved, the practical basis for meeting the statutory requirements on time is lacking. Bitkom, VDMA and ZVEI therefore urge the Federal Ministry for the Environment to declare an immediate enforcement moratorium beyond 15 January. Only this, they argue, can prevent serious problems for manufacturers that could bring the market for batteries and battery-powered products to an abrupt halt.
