Battery Manufacturer Responsibility (ERP)

Take-back obligations for manufacturers, distributors and online retailers.

DIRECTIVE 2006/66/EC - the legal framework for (waste) batteries and (waste) accumulators in Europe

The Battery Act in Germany, BattG for short, transposes the European Framework Directive 2006/66/EC into national law, as do the other national transpositions in other EU states, and defines the handling of batteries, the placing on the market, the return and environmentally sound disposal of batteries and accumulators.

The Battery Directive states that all EU member states with national regulations must establish uniform rules for the handling of batteries and accumulators, e.g. to oblige manufacturers to assume product responsibility for the entire life cycle of the product.

In the European Directive (EU Directive) on the marketing, return and environmentally sound disposal of batteries and accumulators, the European Union defines the associated Extended Producer Responsibility (EPR).

On the basis of this legal foundation, the polluter pays principle and product responsibility, manufacturers and distributors, among others, are assigned responsibility and various obligations, such as the return and environmentally friendly disposal of batteries.

Battery EPR - What am I obligated to do?

Your device contains batteries or a rechargeable battery?

The European Battery Directive regulates the marketing, return and environmentally sound disposal of batteries and accumulators and is incorporated into German law as the Battery Act (BattG). The law obligates various legally defined actors to be product responsible and to comply with and implement a variety of tasks and duties, such as:

Distributors, (online) retailers and fulfillment service providers in the field of batteries and accumulators are also not exempt from the new obligations and are required to carry out checks.

Non-compliance may result in administrative offense proceedings and severe fines, e.g. in Germany of up to €100,000 for all players who do not properly comply with the legal obligations.

Don’t miss out on your legal obligations in the respective EU countries and get in touch now to be informed about the obligations in the respective sales markets and to implement them safely.


Goldleite 9
97234 Reichenberg – Germany
phone +49 931 4523070

Battery types -

What are the differences between battery and accumulator?

The Battery Act (BattG) distinguishes between portable, industrial and automotive batteries (see FAQ Batteries). The law defines primary cells as storage cells for electrical energy that can only be recharged to a limited extent or not at all. Accumulators (rechargeable secondary cells as storage cells for electrical energy) are also considered “batteries” within the meaning of the law.

There are myriad details and interpretations to consider in order to properly capture an obligation. Get in touch with us now to not only stay up to date on all changes relating to batteries (BattG), but also to ensure that your obligations are fulfilled in accordance with the law.

Our services -

Batteries and rechargeable batteries licensing and waste batteries collection and recycling (disposal).

We offer you:

Benefit from our Europe-wide and global networks and expertise.

Our services -

Transport, storage and return of used batteries (hazardous goods such as lithium-ion batteries) and recycling

Various batteries or battery cells can pose major hazards for transport and storage if handled improperly. Li-Ion accumulators in particular can pose an increased fire hazard and are therefore considered hazardous goods under certain conditions. Depending on the size and condition of the batteries and accumulators, different (safety) requirements apply, such as the requirements of the “European Agreement concerning the International Carriage of Dangerous Goods by Road”, or ADR for short.
However, national regulations (e.g. ElektroG in Germany) also apply and must be observed. We are happy to support you in all measures with information material, training and, if required, the necessary dangerous goods officer, so that you can comply with all applicable laws and regulations.

Our network solutions for Europe -

from a single source, take-back systems and recycling partners

National implementations of the Battery Directive (Waste Batteries and Accumulators) lead to many differences in legislation and its implementation that need to be considered.
Do you export to other European countries? Whether for batteries or accumulators, electrical appliances or packaging – we support you with our network solution in your sales countries (sales markets) so that you have the Battery Directive under control.

If you are affected by these obligations, we can guide you through the implementation process by showing you step-by-step the requirements and helping you introduce necessary measures to comply with the laws and regulations.

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Batteries and Accumulators FAQ

Your questions - our answers

The Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators and waste batteries and accumulators regulates the manufacture and disposal of batteries in the European Union. The primary objective of the Battery Directive is to minimise the negative impact of batteries and accumulators and waste batteries and accumulators on the environment, thus contributing to the protection, preservation and improvement of the quality of the environment.

This Directive repeals Directive 91/157/EEC of the European Parliament and of the Council of 18 March 1991 on batteries and accumulators containing certain dangerous substances, which was in force until that date.

Producers, importers and distributors of batteries and accumulators who place batteries on the market for the first time on a professional basis. Basically any initial distributor is affected.
According to 91/157/EEC, a producer is any natural or legal person who places batteries or accumulators, including batteries or accumulators incorporated into appliances or vehicles, on the market within the territory of any EU Member State. This either can be the producer of batteries and accumulators, but also the reseller, irrespective of whether the reseller is established in the respective EU Member State or places on the market of that Member State from a third country.

All relevant definitions can be derived from Article 3of the Battery Directive (EU Directive 2006/66/EC):

  • Portable batteries and accumulators
  • Industrial batteries and accumulators and
  • Automotive batteries and accumulators

You already have to meet specific labelling requirements for your batteries and accumulators in all EU Member States. In addition, we can advise you on your producer responsibility in all EU member states where you have to fulfill further obligations and support you on the registration and reporting process as well as any other administrative requirements.

All Member States ensure that appropriate collection and recycling schemes are in place for waste portable batteries and accumulators. For some types of batteries (e.g. industrial batteries) there are more extensive requirements, on which we will be happy to advise you.

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Documents and Important Legal Bases