The old Battery Directive 2006/66/EC was finally repealed on August 18, 2025. The new Battery Regulation is therefore directly applicable (as an EU regulation) in the individual EU Member States. For some requirements, however, adjustments to the national regulations are necessary - in particular with regard to the management of waste batteries in accordance with Chapter VIII. This should be done until the Battery Directive is repealed.
So far, however, only 4 countries have complied with this implementation. In Germany, this is to be done through the new Battery Implementation Act (BattDG). There is currently a draft bill dated May 27, 2025, which will be voted on by the Bundestag on September 11.
In addition, further comprehensive obligations under the Battery Regulation (EU) 2023/1542 came into force on August 18, 2025.
Labeling:
First of all, according to Art. 13 (5), the relevant chemical symbol indicating the heavy metal content must be affixed below the symbol for "separate collection" (= crossed-out wheelie garbage can) if the content is more than 0.002% cadmium (Cd) or more than 0.004% lead (Pb).
Extended manufacturer responsibility:
Other important innovations relate to extended producer responsibility (EPR). This relates to the individual member states. In Germany, stiftung ear is (still) responsible. There are two important deadlines with innovations that you should note:
August 18, 2025:
- 3 battery types become 5 battery categories
- Existing registrations will be automatically "adjusted"
- Obligation to participate in an organization for producer responsibility (OfH) for each battery category
- Indication of the chemical composition of the batteries
- Indication of the tax ID
- Registration of foreign companies will be deleted
- New application/registration of a domestic authorized representative required
January 16, 2026:
- Selection of an organization for producer responsibility (OfH) for each battery category (latest date)
- Specification of the chemical composition of the batteries (latest date)
- Specification of the tax ID (latest date)
- Existing registration of an authorized representative
- Assurance of proper authorization
Due diligence obligations in the supply chain:
In contrast, the requirements regarding due diligence obligations in the supply chain in accordance with Art. 47 et seq. have been postponed by 2 years to August 18, 2027 as part of the Omnibus IV package with Regulation (EU) 2025/1561.
Do you have questions about the deadlines of the Battery Regulation? We will be happy to provide you with further support. Simply send us an e-mail with your question or use our contact form.
Would you like to read more information about the Battery Regulation? You can find more articles here:
→ Omnibus IV - planned postponement of the due diligence obligations for batteries from May 27, 2025
→ Battery Regulation - practical problems with the classification of light lead batteries from April 30, 2024
Author's note
This article has been machine translated into English.
DEFINITIONS AND ABBREVIATIONS
A regulation applies directly in all member states of the European Union. This so-called "pass-through effect" means that the regulations are applied without further national implementation. It is binding in all its parts and therefore has direct legal effect in every Member State.
A directive under Article 288 TFEU must be transposed into national law by the Member States. While the objective set out in the directive is binding, the specific form and structure of the transposition is left to the Member States.
