On 10 May 2024, the Federal Ministry for the Environment published a draft law to adapt to the new EU Battery Regulation. The EU Battery Regulation (EU-BattVO / (EU) 2023/1542) replaces the EU Battery Directive (2006/66/EC) and has been directly applicable law in Germany since 18 February 2024. The core of the draft is the new Battery Law Implementation Act (BattDG), which is to replace the previous Battery Act (BattG) on 18 August 2025 resp. the Battery Act will cease to apply. Here you will find an extract of the important effects of the BattDG:
- The problem and aim of the draft bill to adapt battery law to Regulation (EU) 2023/1542 are a uniform legal framework, requirements for the production and disposal of batteries, regulations on substance restrictions, design, labelling, conformity and due diligence obligations for batteries as well as the collection and treatment of waste batteries.
- The new legislation incorporates key provisions from the previous BattG.
- The changes mainly concern producer responsibility for batteries.
- All battery producers must participate in a producer responsibility organisation.
- The collective exercise of producer responsibility will be introduced for all battery categories (including industrial batteries).
- The producer obligations are extended to waste batteries for various vehicles (light transport vehicles as well as starter, industrial and electric vehicle batteries).
- A significant increase in the number of authorised take-back systems is to be expected (from the current 9 authorised take-back systems to an anticipated 75 or approx. 15 per category).
- A new obligation to deposit insolvency-proof guarantees (surety, guarantee or by depositing a corresponding amount of money) by the system operators will be introduced in the event that a system is discontinued. The purpose of the security deposit is to finance the subsequent disposal of spent batteries that have a long service life.
- A regular review and adjustment of the security deposit or increase in the event of increasing quantities placed on the market by the battery producers connected to the respective system is planned.
- The possibility of withdrawing the licence in the event of non-compliance with the statutory requirements (failure to meet the statutory collection targets; non-compliance with the order to increase the security deposit) is provided for.
- The collection targets for various battery categories will be adjusted to the EU targets (portable batteries: 63 per cent by the end of 2027 and 73 per cent by the end of 2030; light means of transport (e.g. electric bicycles or e-scooters): 51 per cent by the end of 2028 and 61 per cent by the end of 2031).
- The BattDG sets a higher collection rate for portable batteries in Germany at 50 per cent (EU 45 per cent).
trade-e-bility thus offers a customised, comprehensive online training in which you will learn what requirements the EU Batteries Regulation imposes on you and how to deal with them in your specific case. The training modules include an introduction to the new EU Batteries Regulation as well as comprehensive information on implementing your obligations with regard to labelling, documentation, battery passport, extended producer responsibility and due diligence obligations in the supply chain. Further particulars and advice on EU Batteries Regulation training are available here:
