BattDG in practice: PRO approval missing, deadlines running – what you can do now
There are currently numerous customer enquiries regarding the practical implementation of the new Battery Implementation Act (BattDG).
What this is about:
The new act entered into force on 7 October 2025 and thus replaces the previous Batteries Act (BattG).
Existing battery registrations with stiftung ear must be supplemented with additional information by 15 January 2026, including, among other things, the designation of a so-called Producer Responsibility Organisation (PRO), which will replace the previous take-back systems. If this is not done, the registration will be revoked by stiftung ear (see news).
To date, no PRO has been approved that is open to all producers. Several take-back systems (future PROs) have voiced substantial criticism of the current interpretation and implementation of the BattDG. At the core, they particularly criticise the significantly increased requirements for financial guarantees for PROs as well as the very short implementation period.
Together with other manufacturers’ associations, Bitkom is actively working to develop concrete solution proposals.
What you can do now:
To facilitate the upcoming allocation, please have the following additional information ready:
Tax number of the company registered with stiftung ear.
Battery categories – listing according to the five categories: portable batteries, light means of transport batteries, industrial batteries, starter batteries and electric vehicle batteries.
Chemical composition / chemical system: allocation of each battery category to the respective chemical system (e.g. Li-ion, NiMH, lead, etc.).
Annual quantities (in kilograms), where applicable for the last three calendar years, broken down by battery category.
Overview of which take-back solution you are currently using (own take-back solution or take-back system).
Support from Bitkom
We offer our customers free consultation hours in which our team presents current developments and answers questions.
If you require individual advice, please feel free to contact us. For example, we review your product range and support you throughout the process.
The legal situation is currently very dynamic. We will continue to closely monitor developments and inform you immediately if deadlines or requirements change or if a solution emerges.
