By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Yes: two products, two registrations. Article 3(1), point 47, of Regulation (EU) 2023/1542 makes you the producer of batteries "including those incorporated in appliances" when you sell them in Germany under your brand, import them, or sell them there by distance selling from another country. Article 55(2) and § 4(1) BattDG: no making available, built in or not, without registration. A foreign seller of a cordless drill or a Bluetooth speaker therefore registers the device under the ElektroG and the battery under § 5 BattDG, each through a German representative (§ 8 ElektroG, § 40(2) BattDG). We cover both: WEEE and batteries, €500 a year each. Sources (5)
Regulation (EU) 2023/1542 (BRegulation (EU) 2023/1542 (Batteries)
BattDG § 4BattDG § 4BattDG § 5BattDG § 5BattDG § 40BattDG § 40ElektroG § 8ElektroG § 8
German EPR for batteries built into devices: which category?
You register per battery category, and the category depends on the battery, not on the device it sits in (Article 3(1), points 9 to 14, Regulation (EU) 2023/1542):
| Category | Definition | Typical devices |
|---|---|---|
| Portable battery | Sealed, 5 kg or less, not designed for industrial use, not LMT, SLI or EV | Phones, laptops, toothbrushes, speakers, cordless tools, toys |
| LMT battery | Sealed, 25 kg or less, powers the traction of light vehicles such as e-bikes and e-scooters | E-bikes, e-scooters, electric unicycles |
| SLI battery | For starting, lighting or ignition of vehicles or machinery | Car, motorcycle and boat starter batteries |
| Industrial battery | Designed for industrial use, or over 5 kg and none of the others | Home storage systems, large power stations, forklifts |
| Electric vehicle battery | Powers the traction of cars, vans and trucks, or of L-category vehicles above 25 kg | Electric cars, heavy e-motorcycles |
A device with a lithium-ion pack under 5 kg is almost always a portable battery. The chemistry is declared too (Article 55(3)(c)).
What a device seller has to do for the battery
- Appoint a representative for batteries if you have no establishment in Germany: one, in writing and in German (§ 40(2) BattDG). It can be the same company as your WEEE representative, under a separate mandate.
- Register by brand and battery category through the authority's online system before the first sale (§ 5(1) and (2) BattDG). The application lists your trade register and tax numbers, the categories and chemistries, and how you meet your producer responsibility (Article 55(3)).
- Join an organisation for producer responsibility for portable and LMT batteries, or fulfil the duty individually, and tell it the mass you made available in each of the last three years (§ 7 BattDG): see joining an organisation.
- Wait for the registration. It is deemed granted twelve weeks after a complete application (§ 5(1)): see registration time.
BattDG § 40 BattDG § 5 BattDG § 7 Regulation (EU) 2023/1542 (B
What changes on 18 February 2027
- Removable batteries. Products with portable batteries must let the end user remove and replace the battery with commercially available tools (Article 11, applicable from 18 February 2027 under Article 96), subject to the exceptions in Article 11.
- QR code. All batteries carry a QR code giving access to their information (Article 13(6)).
Four common mistakes
- Thinking the WEEE registration covers the battery. It does not: the ElektroG registers the device, the BattDG the battery.
- Relying on the cell maker's registration. The producer is whoever makes the battery available in Germany first, built in or not, under the rules of Article 3(1), point 47; the cell maker's registration in another country does not cover your sales.
- Forgetting the spare battery. Batteries sold separately as spare parts or packed with the device are registered the same way.
- Selling while unregistered. Marketplaces must not offer and fulfilment providers must not store, pack or ship batteries of an unregistered producer (§ 4(3) BattDG), and a dealer who knowingly sells them becomes a producer itself (§ 3 No. 1).
Regulation (EU) 2023/1542 (B BattDG § 3 BattDG § 4
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