Germany’s BattDG: Battery Producer Compliance Deadline – January 15, 2026
Germany has now moved fully to its new Battery Act (BattDG), updating national requirements in line with the EU Battery Regulation. While the regulation introduces some new concepts and tighter controls, its overall aim is to bring more clarity and consistency to battery compliance in Germany.
For producers, one key point to note is that all registrations need to be transitioned and linked to an OfH by 15 January. With proper planning and support, this can be done smoothly without disrupting your operations.
What’s Changed Under BattDG?
At the center of the new framework is a revised approach to Extended Producer Responsibility. Compliance is now organised through Organisaplaysen für Herstellerverantwh play a much more central role than under the previous system. OfH is the German equivalent to a Producer Responsibility Organization (PRO) Participation in an OfH is no longer a formality; it is essential to keeping registrations valid.
BattDG also expands and clarifies battery categories. Registration and compliance are handled separately for portable, industrial, SLI (starter), electric vehicle (EV) and light means of transport (LMT) batteries. For companies with a broad product range, this category-based logic makes correct allocation more important than ever.
Transition Period – and Why Timing Matters
Existing registrations under the old Battery Act do not disappear overnight, but they do need to be actively transitioned. The regulation includes a defined transition phase, with a hard cut-off on 15 January.
By this date, producers must ensure that:
- Each relevant battery category is correctly assigned to an OfH
- Producer and battery master data in the register is complete and up to date
- Existing registrations are aligned with the new BattDG requirements
Even if part of a portfolio is compliant, gaps in a single battery category can still create risk. Taking a structured, category-by-category approach is the safest way to manage the transition.
Registration Still Applies to All Battery Types
Registration via the Stiftung ear register remains mandatory before batteries can be placed on the German market. Under BattDG, this requirement clearly applies to all battery categories, not just portable or consumer batteries.
The register itself has also become more data-driven. Incomplete or inconsistent information can delay approval or trigger follow-up questions from authorities, making data quality an increasingly important part of battery compliance.
For producers not established in Germany, the obligation to appoint a German authorized representative (Bevollmächtigter) remains unchanged and is still a prerequisite for registration.
How RLG Supports a Smooth BattDG Transition
RLG supports producers at every stage of battery compliance in Germany, starting with confirming producer status and scope. This includes identifying the correct producer model, mapping products to the right battery categories, and managing Stiftung ear registrations, whether new or existing.
RLG also supports OfH selection, onboarding, and correct assignment per battery category, helping ensure registrations remain valid throughout the transition. Beyond registration, RLG helps set up efficient processes for battery master data, quantity reporting, and audit-ready documentation. For non-German producers, RLG provides a clear and practical pathway to appointing and operationalizing a German authorized representative.
Through Rebat, RLG provides an end-to-end take-back and recycling solution for batteries in Germany. Rebat is the largest take-back system in Germany for portable batteries and offers tailored solutions for other battery categories. By joining Rebat, producers can meet their extended producer responsibility obligations under the Battery Act, including registration, take-back, and reporting requirements.
If registrations are not transitioned and correctly linked to an OfH for each relevant battery category by 15 January, there is a risk of registration withdrawal and market disruption. With the right planning and support, the BattDG transition can be managed efficiently, and RLG can support the process end-to-end.
