Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
A battery producer with no establishment in Germany must appoint an authorised representative for extended producer responsibility, who registers it by brand and battery category before the first sale (§§ 5 and 40 BattDG). Batteries built into or packed with a device count. We act as your representative for €500 a year. Sources (2)
BattDG § 4BattDG § 4BattDG § 5BattDG § 5
What the law asks
| Duty | Law | Who |
|---|---|---|
| Appoint one representative, in writing and in German | BattDG § 40(2) | You |
| Register by brand and battery category | BattDG § 5 | The representative |
| Take-back through an organisation for producer responsibility | Regulation (EU) 2023/1542 | The representative, at your cost |
The representative performs these duties in its own name.
Selling before registration
Producers may only make batteries available once registered. Without registration, retailers may not sell them and fulfilment providers may not store, pack or ship them.
What we need from you
- Brands, and the battery category of each (portable, starter, industrial, electric vehicle or light means of transport)
- Whether the batteries are sold alone, built in or packed with a device
- Expected quantities per year
Price
€500 a year for the representation. The organisation for producer responsibility charges its own fees, passed on at cost.
Germany batteries authorised representative service: what we do
- You sign a mandate in German for your batteries (BattDG § 40(2)).
- We register you by brand and battery category, including batteries built into or packed with a device (§ 5).
- We join an organisation for producer responsibility for take-back; its fees are passed on at cost.
- We file the quantity reports from your figures.
€500 a year for the representation. A device with a built-in battery usually needs the electrical equipment registration as well.
Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
Razvan on LinkedIn ↗