By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Yes, without a German establishment. § 40(2) BattDG: appoint an authorised representative for extended producer responsibility (Bevollmächtigter für die erweiterte Herstellerverantwortung), only one, in writing and in German; it acts in its own name. § 5(1): registration by brand and battery category under Article 55 of Regulation (EU) 2023/1542 before the first making available. § 4(1): no making available without that registration. We act as your battery representative for €500 a year. Sources (3)
BattDG § 40BattDG § 40BattDG § 5BattDG § 5BattDG § 4BattDG § 4
Battery registration in Germany through a BattDG authorised representative, step by step
- Mandate. One representative for extended producer responsibility, in writing and in German. It carries out your duties in its own name (§ 40(2) BattDG).
- Organisation for producer responsibility. For portable and LMT batteries you join one per category, or fulfil the duty individually (§ 7(1)).
- Application. Your representative applies through the authority's online system (§ 5(2)) with the details Article 55(3) of Regulation (EU) 2023/1542 lists.
- Registration. Deemed granted twelve weeks after the complete application, unless refused (§ 5(1)).
- Selling. Only from then on, for loose batteries and for batteries built into products alike (§ 4(1), Article 55(2)).
The official fees are €16.40 per brand and battery category and €3.80 per registration number and calendar quarter (ElektroGBattDGGebV, Nos. 2.1 and 2.2).
BattDG § 40 BattDG § 7 BattDG § 5 BattDG § 4 
Regulation (EU) 2023/1542 (B ElektroGBattDGGebV, fee sche
What your representative needs from you
- Company name, brand names, address, phone, web and email, with one contact point (Article 55(3)(a)).
- Trade register number and the European or national tax number (Article 55(3)(b)).
- The battery categories you sell in Germany and their chemistry (Article 55(3)(c)).
- The organisation for producer responsibility you joined, with its details, or how you meet the duty yourself (Article 55(3)(d)).
- The mass of batteries made available in Germany in each of the three previous calendar years, for the organisation (§ 7(2) BattDG).
Selling devices with built-in batteries? See batteries built into devices.
Regulation (EU) 2023/1542 (B BattDG § 7
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