Battery Information
The New Industrial Battery Act: A Guide for Manufacturers and Distributors of Industrial Batteries
The Battery Law Implementation Act (BattDG) is the primary German law implementing Regulation (EU) 2023/1542 on batteries and used batteries. It regulates the entire life cycle of batteries—from placing them on the market through take-back to environmentally sound recycling.
Who is considered a manufacturer or distributor?
Under the law, a “manufacturer” is defined as any person who, on a commercial basis, offers batteries for sale in Germany for the first time or places them on the market(regardless of whether they are installed in appliances or vehicles). In addition to domestic production, this explicitly includes the importand resale of unregistered brands.
Focus on Industrial Batteries: What Does This Encompass?
In the photovoltaic industry, industrial batteriesare particularly relevant. These include batteries designed for industrial applications, such as stationary energy storage systems. From a technological standpoint, modern systems such as lithium-ion (Li-ion)and lithium iron phosphate (LFP)are currently at the forefront.
Your key responsibilities as a distributor
Anyone who places batteries on the market is subject to extended producer responsibility (EPR). The BattDG establishes the following obligations in this regard:
• Registration requirement:Before batteries can be sold, manufacturers must register all their brands and categories with the ear Foundation. Any violation automatically results in a sales ban.
• OfH Beteiligungspflicht: Als Inverkehrbringer müssen Sie einer für Ihre Batteriekategorie zugelassenen Organisation für Herstellerverantwortung angehören (Link einfügen „Mitglied werden“
• Nationwide collection:You are required to ensure that used industrial batteries can be returnednationwide throughout Germany in a manner that is reasonable, non-discriminatory, and completely free of chargeto the end user.
• Financial responsibility:The manufacturer bears all costs associated with collection, ADR-compliant transport, logistics, and proper recycling.
• Material recovery:All collected batteries must be sent to state-of-the-art, certified treatment and recycling facilities.
• Reporting requirements:There is a requirement to submit regular and annual reports on the quantities placed on the market, as well as on the used batteries collected and recycled.
Risks Associated with Non-Compliance
Violations of the BattDG are no trivial matter. They can result in fines of up to €100,000, the forfeiture of profits, and warnings under competition law.
PV CYCLE: Your authorized organization for producer responsibility (OfH)
For individual companies, meeting these complex requirements often involves a significant administrative burden. However, manufacturers can delegate these obligations to a Manufacturer Responsibility Organization (MRO).
PV CYCLE Deutschland GmbH is your specialized waste management company for industrial batteries. We offer you a legally compliant, comprehensive solution:
• Full compliance: We handle registration, data management, and regulatory reporting in accordance with Article 75 of the EU Battery Regulation on your behalf.
• Efficient logistics: We guarantee comprehensive collection of used industrial batteries within a maximum of 10 business days afternotification—safely and in compliance with ADR regulations.
• Safety Guarantee: Our system is specifically designed to meet the requirements of lithium-ion systems (Li-Ion/LFP)and is regularly inspected by independent experts.
• Transparency: Through our electronic reporting portal, you can keep track of your material flows at all times.
Leave your compliance to the experts.
By joining the PV CYCLE producer responsibility organization, you can easily fulfill your legal obligations