Selling batteries into Germany? Without a German representative, your registration gets cancelled

What changed in October 2025

The old German battery act (BattG) was replaced by the BattDG, the national law implementing the EU Battery Regulation. Two changes matter most for foreign sellers:

• The competent authority is now stiftung ear — the same foundation that runs Germany's WEEE register — and it applies the rules strictly.
• For producers without a German establishment, appointing a German Authorised Representative is mandatory, not optional. No representative, no registration; no registration, no lawful sales.

This applies not only to battery brands: if your product contains a battery — electronics, toys, tools, e-mobility accessories — you are a battery producer in the eyes of the law.

Why sellers are discovering this the hard way

Registrations made under the old law by foreign producers without a representative have been removed from the register. Sellers first notice when a marketplace flags the missing registration or a competitor sends a cease-and-desist letter. Fines for missing or incorrect registration reach €100,000, alongside sales bans and civil exposure.

What compliance actually involves

1. Appointing a German representative — the representative registers with stiftung ear on your behalf and becomes your legal interface in Germany.
2. Category-by-category registration — the law distinguishes five battery categories (portable, LMT, EV, industrial, starter batteries). Each category you place on the market is registered separately, including chemistry details.
3. Take-back participation — for portable batteries, membership in an approved take-back scheme (OfH) is required, and your reported quantities are cross-checked with the scheme.
4. Ongoing reporting — quantity reports on a fixed calendar, which your representative manages.

Why battery representation costs more than packaging

A fair question sellers ask: our packaging module is €390/year, batteries €890. The difference is real work and real risk — five separate category registrations, chemistry documentation, OfH coordination, and a representative who carries responsibility for the accuracy of it all. Providers who quote battery representation at packaging prices are usually not doing the work.

This guide is general information, not legal advice. Regulatory details can change; obligations depend on your specific setup. MainCompliance UG (haftungsbeschränkt) i.G., Bad Kreuznach, Germany.