Battery compliance: Key changes and developments in 2025
2025 was a pivotal transition year for battery compliance in Germany and particularly challenging for manufacturers. With the adaptation to the EU Battery Regulation, registrations with stiftung ear were restructured, additional mandatory information was introduced, and the new Battery Implementation Act (BattDG) was adopted.
Similar adjustments to battery legislation were also made in other countries, and further changes are still planned for this year. For manufacturers, importers, and distributors, this primarily meant new categories, new evidence requirements, and a significantly increased documentation burden.
New battery registration: five categories and more mandatory information
Battery registration in Germany was expanded in terms of content and technically restructured in 2025. As a result, five battery categories now apply instead of three. At the same time, new mandatory information became binding in the ear portal, in particular:
chemical composition
tax identification number
designation of an Producer Responsibility Organisation (PRO)
This has made registration significantly more detailed – and errors or missing information may now more quickly lead to revocations.
Foreign manufacturers: registration only with an authorised representative
A key tightening affects foreign manufacturers: direct registration without a representative is no longer possible in Germany. Instead, an authorised representative based in Germany is mandatory. Existing registrations without an authorised representative were revoked accordingly.
The introduction of an authorised representative is in line with the new EU Battery Regulation (BattVO) and will also become mandatory in other EU countries in the future.
In Denmark, foreign manufacturers who sell batteries directly to end customers in Denmark have, since September 2025, been subject to registration for the first time and must appoint an authorised representative in Denmark to fulfil the obligations (see news).
BattDG: New German battery law enters into force
On 7 October 2025, the Battery Implementation Act (BattDG) also entered into force. The new law aligns German battery legislation with the EU Battery Regulation, which comprehensively regulates the entire life cycle of batteries – from production and distribution to disposal. Particularly relevant aspects include:
an expanded definition of “producer” (distributors may, under certain circumstances, be considered producers themselves),
the option to fulfil take-back obligations collectively via an PRO (or alternatively on an individual basis),
a national collection rate of 50% for waste portable batteries,
the introduction of a waste battery commission as a new advisory body.
What needs to be done now?
1) Review registration status by country
Does my company have producer obligations? Have current regulatory developments as well as changes to the distribution model already been taken into account?
Are all national battery registrations active and valid?
Has all mandatory information been provided (chemistry, tax ID, category)?
Is the PRO correctly designated and confirmed for each category?
2) Correctly assign battery categories
Since five categories have applied in Germany since 2025, correct classification is crucial – both for registration and for evidence and fee models. The categories still differ slightly from country to country, so classification must be reviewed on a per-country basis. In some countries, such as Switzerland (with Inobat) or France (with Batribox), new web portals have also been introduced, which manufacturers should now use, among other things, for their quantity reporting.
3) Ensure PRO contracts for each category
For each category, the following applies: without participation in an PRO (or an individual solution), no registration with stiftung ear will take place. Are valid contracts with collective take-back systems also in place in other countries?
4) Foreign manufacturers: observe the authorised representative requirement
Anyone without an authorised representative based in Germany cannot be validly registered. This requirement will also apply in the future in other EU Member States.
Due to the expanded definition of producer, the risk for retailers is increasing: anyone distributing batteries from manufacturers that are not correctly registered may themselves be considered a producer. Supply chains and evidence should therefore be reviewed consistently.
If you have any questions, feel free to register here for one of our upcoming seminars or book the EPR Compliance Quick Check directly.
