BattDG Germany – Battery Producer Deadline January 15, 2026

Germany has introduced strict new rules for battery producers with a critical deadline fast approaching. Companies that fail to act in time risk losing their market access entirely. Here is what you need to know to stay compliant under the new German battery law.

What Is the BattDG and Why Does It Matter

The BattDG (Batterie-Recht-Durchführungsgesetz) is Germany’s national implementation act for the EU Battery Regulation. It requires all battery producers to re-register and affiliate with an approved Producer Responsibility Organisation by January 15, 2026. Having entered into force in October 2025, the BattDG completely replaces the previous German Batteries Act (BattG).

Unlike its predecessor, the new law covers the entire lifecycle of batteries. From registration through labelling to take-back and recycling, the BattDG governs every step. It transposes the requirements of EU Battery Regulation 2023/1542 into national law while adding Germany-specific provisions.

For companies placing batteries on the German market, there is no room for interpretation. The BattDG applies to all producers regardless of company size or battery type. Those who ignore the new obligations face severe consequences that extend far beyond monetary fines.

The January 15, 2026 Deadline Explained

January 15, 2026 marks a decisive cut-off date in German battery law. All existing registrations under the old BattG lose their validity on this day. Producers must transfer their registration to the new system and demonstrate participation in a Producer Responsibility Organisation (OfH).

Those who fail to complete this transition in time will have their registration deemed retroactively revoked as of January 1, 2026. This means affected companies will legally be treated as if they never held a valid registration, even two weeks before the actual deadline. The Stiftung EAR will perform portal maintenance on January 16, 2026, during which incomplete registrations will be removed.

No deadline extension is currently planned. Authorities have made clear that the cut-off date is binding. Companies should therefore not speculate on last-minute solutions but complete their registration as early as possible.

What Happens If You Miss the Deadline

The consequences of missing the BattDG deadline are severe and take effect immediately. Under § 4 BattDG, an instant sales ban applies to all batteries from the affected producer. This ban extends beyond the producer to the entire distribution chain.

Distributors and fulfilment service providers may neither store nor ship batteries from unregistered producers. Each violation can result in fines exceeding €100,000. Additionally, competitors and consumer protection associations may pursue legal action.

The economic damage extends far beyond direct penalties. Supply contracts cannot be fulfilled, customer relationships suffer, and re-entering the market requires a complete new registration process. This typically takes several weeks, during which no sales are possible.

New Battery Categories Under BattDG

The BattDG introduces an expanded category system replacing the previous three-way division. Instead of three categories, there are now five clearly defined battery categories, each requiring separate registration. This reorganisation reflects technological developments, particularly the rise of electric mobility.

Each category is subject to its own requirements regarding collection targets, labelling and recycling. Incorrect classification can invalidate the registration. Producers should carefully analyse their product portfolio and seek professional advice if uncertain.

Correct categorisation is not merely a formal obligation but has practical implications for the entire compliance strategy. From choosing the right OfH to designing product labels, many decisions depend on the battery category.

Category	Examples	Key Features
Portable batteries	Smartphones, laptops, tools	Collection target 63% by 2027
SLI batteries	Vehicle starters, lighting	Strict recycling requirements
LMT batteries	E-bikes, e-scooters	New category, collection target 51% by 2028
EV batteries	Electric vehicles	Battery passport from 2027
Industrial batteries	Energy storage, facilities	CO₂ declaration required

Registration Requirements for Battery Producers

Registration under the BattDG demands more than the previous system. Producers must provide comprehensive information and support their statements with documentation. Incomplete registrations are not accepted and lead to rejection.

Mandatory Information for Registration

Required information includes first and foremost the chosen Producer Responsibility Organisation. Without OfH membership, registration is not possible unless the producer holds approval for individual take-back. Such approval is granted only in exceptional cases and requires proof of appropriate infrastructure.

The BattDG additionally requires detailed information on the chemical composition of batteries. Producers must disclose the substances contained and their proportions. The company’s tax identification number and all brand names under which batteries are marketed must also be provided.

Requirements for Foreign Producers

Special rules apply to companies based outside Germany. Direct registration is no longer permitted under the BattDG. Foreign producers must appoint a Germany-based authorised representative who assumes full responsibility for all compliance obligations.

The authorised representative serves as the legal contact for authorities and is liable for violations by the foreign producer. Appointment was originally required by August 18, 2025. Those who missed this deadline should act immediately, as no registration and thus no market access is possible without an authorised representative.

The Role of Producer Responsibility Organisations (OfH)

Producer Responsibility Organisations form the backbone of the new BattDG system. These organisations, approved by the Stiftung EAR, assume collection, take-back and recycling obligations on behalf of affiliated producers. From January 16, 2026, battery take-back in Germany is only possible through an OfH or approved individual take-back solutions.

Choosing the right OfH deserves careful consideration. Different organisations offer varying service scopes and pricing models. Beyond pure costs, producers should factor in service quality, reporting capabilities and accessibility when making their decision.

Joining an OfH requires concluding a participation agreement. The organisation then reports participation to the Stiftung EAR, which links this information to the producer registration. Only when both systems are synchronised is the registration considered complete. This process can take several days, so sufficient lead time should be planned.

How the BattDG Affects Distributors and Fulfilment Providers

The BattDG affects not only producers but the entire distribution chain. Distributors and fulfilment service providers share responsibility for compliance with legal requirements. Those who sell or store batteries from unregistered producers become liable themselves.

Before adding new suppliers to the portfolio, verification of registration is mandatory. The Stiftung EAR provides a publicly accessible database where valid registrations can be checked. This verification should be documented and repeated regularly, as registrations can expire at any time.

Fulfilment providers face particular challenges. They store and ship goods on behalf of their clients without always having full transparency regarding compliance status. Experienced logistics partners therefore implement systematic verification processes and support their clients in meeting all BattDG requirements. Close cooperation between producer and fulfilment provider minimises risks for both parties.

Steps to Ensure BattDG Compliance Before January 2026

The remaining time until the deadline should be used effectively. A structured approach prevents last-minute stress and ensures no requirements are overlooked. The following checklists provide guidance for producers and distributors.

Compliance Checklist for Producers

First, verify the current registration status with the Stiftung EAR. Old registrations under the BattG must be transferred to the new system. Simultaneously, all battery products should be assigned to the correct categories, as separate registration is required for each category.

Selecting and joining a suitable OfH forms the next step. The required documents must be compiled: information on chemical composition, tax ID and brand details. After concluding the contract with the OfH, final registration takes place, which must be completed before January 15, 2026.

Compliance Checklist for Distributors

Distributors should verify and document the registrations of all battery suppliers. Proof of valid BattDG registration should be requested from each supplier. This verification protects against unintentional violations and potential legal action.

Additionally, developing contingency plans for cases where suppliers lose their registration is advisable. Alternative sources should be identified and stock levels of critical products increased if necessary before the deadline expires.

Frequently Asked Questions About the BattDG

What Is the BattDG?

The BattDG (Batterie-Recht-Durchführungsgesetz) is Germany’s implementation act for the EU Battery Regulation. It governs registration, labelling, take-back and recycling of batteries and has been in force since October 2025. The BattDG replaces the previous German Batteries Act (BattG) and places significantly higher demands on producers and distribution partners.

When Is the BattDG Registration Deadline?

All battery producers must transfer their registration to the new system and demonstrate OfH participation by January 15, 2026. Registrations not updated by this deadline are deemed retroactively revoked as of January 1, 2026.

What Happens If a Producer Misses the Deadline?

Non-compliant producers receive an immediate sales ban under § 4 BattDG. Distributors and fulfilment providers may no longer handle their products. Fines can exceed €100,000. Re-entering the market requires complete new registration.

Can Foreign Companies Register Directly Under BattDG?

No. Foreign producers must appoint a Germany-based authorised representative who assumes full compliance responsibility. Without an authorised representative, registration under the BattDG is not possible.

What Is an OfH Under the BattDG?

An OfH (Organisation für Herstellerverantwortung) is an organisation approved by the Stiftung EAR that fulfils collection and recycling obligations on behalf of battery producers. From January 2026, participation in an OfH or approved individual take-back is a prerequisite for market access.