Battery Compliance in Germany

A manufacturer according to the BattG is:

A manufacturer is anyone who sells batteries in Germany for the first time, regardless of how they do so. Distributors and intermediaries who offer batteries from manufacturers who are not properly registered are also considered manufacturers.

Manufacturers based abroad are also required to register. However, if they do not have a branch in Germany, they can appoint an authorised representative to take on the legal obligations.

Special manufacturer constellations:
Battery sets

For battery cells that are used exclusively for assembly in battery sets, it is not the manufacturer of the battery cells who must register, but the manufacturer of the battery set.

Built-in batteries

If batteries are integrated into other products, the manufacturer of the battery is often different from the manufacturer of the product.

If the battery bears the same brand name as the product or was manufactured according to the product manufacturer’s specific requirements, the product manufacturer is also responsible for registering the battery. This also applies if only the product brand name is visible to the customer at first glance.
If the brand of the battery differs from that of the product and this is also recognisable, the manufacturer of the battery is responsible for registration.
Private label batteries

If batteries are manufactured by a third party specifically for commercial enterprises under their own brand name, the commercial enterprise is responsible for registering the batteries. The same applies if batteries are manufactured specifically for other clients. In this case, the client is also required to register.

Import of batteries for use in commercial operations

If batteries are imported from abroad for use in your own commercial operations, the foreign supplier is required to register as the manufacturer.

All batteries are covered by the BattG. This does not apply if a battery is explicitly excluded.

Batteries are sources of electrical energy consisting of one or more non-rechargeable primary cells or rechargeable secondary cells, which are obtained by the direct conversion of chemical energy.

The BattG also applies to

batteries that are incorporated into other products or included with other products
Battery sets
A battery set is a group of batteries that are connected to each other or assembled in an outer casing in such a way that they form a complete unit that cannot be separated or opened by the end user.
Note: Electrical appliances that contain batteries do not fall within the scope of the BattG. They are subject to the ElektroG.

Before you can place batteries on the market in Germany, you must register as a manufacturer with the stiftung ear authority. This registration begins with the creation of a user account and the submission of a registration application on the ear portal.

Battery registration is a legally required approval that must be actively applied for and is necessary for placing device batteries, vehicle batteries and industrial batteries on the market.

Step 1 – Create a user account with the ear foundation

Step 2 – Create an authorised representative* and enter payment details

Step 3 – Apply for battery registration

Step 4 – Enter the brand and battery type

Step 5 – Submit application

Step 6 – Receive registration notification

*In this case, the authorised representative would be Bitkom.