Germany
Where battery producers register in Germany
Germany polices batteries EPR at the warehouse door. Under the BattDG, fulfilment providers may not store, pack or ship batteries for producers missing from the register, so batteries EPR in Germany decides whether your logistics run at all.
The register is stiftung ear, and the sequence is strict. You need the registration decision, the Registrierungsbescheid, in hand before your first battery is placed on the German market.
The ear portal carries the application itself, and registration counts as granted after 12 weeks if the requirements are met.
The register charges a fee per brand and battery type, 16.40 euros net, and the recurring money is whatever your OfH charges once you anchor in one for each battery category you sell.
The German reporting rhythm
You report to your OfH, not to a ministry. Once a year it collects your battery categories and the mass you placed on the German market in each of the three preceding calendar years.
The OfH then files consolidated, expert-confirmed documentation by 30 June. Between filings it can request the underlying information, and the BattDG requires ecological criteria to be considered when contributions are set.
Selling from abroad adds one document. A producer without a German establishment must appoint exactly one authorised representative, in writing and in German, and that Bevollmächtigter can carry the registration itself.
The German definition of a battery producer
The duty reaches well past the factory gate. Across EPR in Germany the trigger is placing products on the market, and for batteries that catches you when any of these fit:
- You place batteries on the German market for the first time, from the first unit sold.
- You sell devices with batteries built in, which makes you a battery producer and a WEEE producer at the same time.
- You sell into Germany without a German establishment, which adds the mandatory representative.
- You sell starter batteries at a distance, which brings a deposit duty of its own.
Starter batteries carry a deposit of 7.50 euros including VAT. Retailers charge it when no old battery comes back, and distance sellers refund it against a collection-point confirmation no older than two weeks.
How Germany polices battery EPR
Selling without registration is banned outright under § 4 BattDG. The fine ceiling for market bans, registration and reporting failures is 100,000 euros, and violating enforceable supply-chain due-diligence orders goes up to 500,000 euros.
The law never orders marketplaces to check battery registration numbers. When a platform demands yours, that is platform policy, and the legal gate stays where the BattDG put it, at the fulfilment warehouse.
From national law to EU rules in Germany
The BattDG is Germany's implementation of the EU Battery Regulation, and the EU layer carries the next dates. From 18 February 2027 portable batteries must be removable and replaceable by the user, and EV, LMT and industrial batteries above 2 kWh get a battery passport.
The collection targets are dated too. Portable batteries must hit 63 percent by the end of 2027 and 73 percent by the end of 2030, with LMT batteries at 51 percent by the end of 2028 and 61 percent by the end of 2031.
Frequently asked questions about German battery EPR
The questions battery sellers ask most about the German rules.
Who has to register for batteries EPR in Germany?
Anyone placing batteries on the German market, including brands whose devices ship with batteries built in. Registration runs through the ear portal per brand and battery category, anchored in an approved OfH, and must be complete before the first battery ships.
Is there a threshold or exemption for small producers?
No. The Registrierungsbescheid must exist before the first battery is placed on the German market, and the EU battery regime has no de minimis for producer registration anywhere.
Do foreign or online sellers need an authorised representative in Germany?
Producers without a German establishment must appoint exactly one Bevollmächtigter, in writing and in German. The representative can handle the registration, and without one there is no legal route onto the German market.
What happens if I sell without registering?
The sale itself is illegal under § 4 BattDG, fines reach 100,000 euros, and fulfilment providers are barred from storing or shipping your batteries. Platforms may also demand a registration number as their own policy.
What changes next for batteries EPR in Germany?
The EU Battery Regulation adds user-removable portable batteries from 18 February 2027 and battery passports for EV, LMT and large industrial batteries above 2 kWh. Collection targets step up next, starting with 63 percent for portables by the end of 2027.
