New Battery Law and EU Regulation: What Manufacturers and Distributors Need to Know

A robust circular economy for batteries is the aim of the new EU-wide regulations. Through the EU Battery Regulation, harmonised standards are established across the entire lifecycle: from raw material sourcing and production to use, collection, recycling and reuse. The objective is to reduce environmental impacts, recover valuable resources more efficiently and significantly increase transparency in battery management. Obligations relating to labelling, CO₂ footprint reporting and supply chain due diligence are being expanded step by step according to a defined timetable.

The new BattDG: Producer Responsibility with the PRO

Special emphasis is placed on extended producer responsibility. With the new BattDG, the Producer Responsibility Organisation (PRO) becomes a central player: Since 1 January 2026, end-of-life batteries may only be collected and treated by approved PROs. Placing batteries on the market without being assigned to a PRO is no longer legally permitted. The PRO therefore replaces previous individual or collective take-back systems and assumes numerous obligations on behalf of manufacturers: from establishing free collection points and ensuring proper treatment and recycling to providing financial guarantees and fulfilling reporting and transparency obligations towards authorities and end users.

Obligations at a glance: What companies need to do now

Manufacturers and distributors must, in particular:

• Register with Stiftung ear and regularly update their registration (BattDG).
• Join an approved Producer Responsibility Organisation (PRO) in order to ensure compliance with statutory take-back and recycling obligations (BattDG).
• Maintain technical documentation for each battery placed on the market in accordance with Regulation (EU) 2023/1542 (including safety data, material composition, hazardous substances and conformity assessment).
• Fulfil information obligations towards end customers, e.g. regarding proper disposal, return options and minimum lifespan.
• Since 18 February 2025, provide a carbon footprint declaration for EV batteries, LMT batteries and rechargeable industrial batteries with a capacity above 2 kWh.
• From 18 August 2026, comply with labelling and information requirements regarding capacity, collection, chemical composition and manufacturer identification.
• From 18 August 2028, indicate recycled content levels of certain metals (e.g. cobalt, lithium, nickel and lead) in the technical documentation.

Additional obligations for other market players

Importers, retailers and recyclers are also subject to the new requirements. Importers are often legally considered manufacturers and therefore must also comply with registration, labelling and product documentation obligations. Retailers and distributors must take back end-of-life batteries, properly inform consumers and continue to charge deposits for starter batteries. Recyclers and waste management companies must comply with requirements for treatment, recovery and reporting.

Timeline: Key Milestones

Since January 2026, participation in an approved PRO is mandatory for all battery categories – without being assigned to a PRO, batteries may no longer be legally placed on the German market. In the following years, additional requirements will gradually enter into force, including further reporting obligations, expanded labelling requirements (such as the digital battery passport), and binding minimum levels for recycled content.

Interzero PRO: Your Implementation Partner

As a licensed PRO, Interzero supports manufacturers, distributors and other market participants such as retailers in implementing all new requirements. We register your batteries with Stiftung ear, organise nationwide collection and take-back schemes, and ensure transparent reporting in line with legal requirements. We also support you with additional obligations such as carbon footprint reporting, supply chain due diligence and the digital battery passport.

For foreign companies with obligations in Germany, Interzero already acts as an authorised representative, assuming all necessary EPR responsibilities.

Make use of our expertise to master these new challenges and align your processes to be both sustainable and future-proof.

Do you have questions or need support with implementation? Contact our team of experts at sales.epr@interzero.de.