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Do I have to join a battery take-back organisation in Germany?

Yes, or fulfil your responsibility individually. § 7(1) BattDG; you declare to it your battery category and the mass of the last three years.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

Yes, per category, or you go it alone. § 7(1) BattDG: participate in an organisation for producer responsibility (Organisation für Herstellerverantwortung) for each battery category, or fulfil the duty individually. § 7(2): give it the category and the mass made available in Germany in each of the previous three calendar years, updated yearly; it confirms the participation and quantity, and both notify the authority. § 5(1) sentence 2: your own registration stays your duty, or your representative's, even with an organisation appointed. If the organisation loses its approval, your participation counts as not made from that date (§ 7(3)).

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