Alongside the GPSR, PPWR and EUDR, another product compliance obligation has become fully operational: Germany's Battery Law Implementation Act (BattDG). It replaced the previous battery act on 7 October 2025 (German Environment Agency) and transposes the enforcement of the EU Battery Regulation into national law. For anyone running an online shop, this is not a side issue: sellers of devices with built-in batteries, power tools, electronics, e-mobility products or toys are affected - often without realising it. This practical guide explains who qualifies as a producer under the act, which notice and labelling duties have to be implemented technically in the shop, how to maintain those details through attribute sets instead of copy-paste, and what data model the battery passport will require from February 2027.
What the new battery law changes for online shops
The legal basis is Regulation (EU) 2023/1542 concerning batteries and waste batteries (EUR-Lex). It applies directly in all member states and takes effect in stages - the waste-related provisions since 18 August 2025 (German Environment Agency). To enforce the European framework in Germany, a national implementation act was required: the BattDG entered into force on 7 October 2025 and fully replaced the old battery act (German Environment Agency). The competent authority for registration and approvals remains the Stiftung Elektro-Altgeräte Register, which the German Environment Agency has again entrusted with sovereign tasks (German Environment Agency).
Existing registrations were migrated automatically, but had to be supplemented by 15 January 2026 with additional details such as the chemical composition of the batteries and the tax number, and assigned to an approved producer responsibility organisation (stiftung ear). Where that proof was not provided, the affected registrations are deemed revoked retroactively as of 1 January 2026 (Section 64(7) BattDG, gesetze-im-internet.de). Anyone who has not acted is currently selling without a valid registration.
Substantively, the new law reorganises the market: the three previous battery types have become five battery categories - portable batteries, batteries for light means of transport (LMT batteries), starter batteries, industrial batteries and electric vehicle batteries (IHK). This categorisation is not an administrative detail but the key to everything else: registration, participation in a producer responsibility organisation, take-back route and labelling all depend on the category. If it is not held in the product record, the duties cannot be rendered cleanly.
| Aspect | Previously (BattG) | Under the BattDG |
|---|---|---|
| Classification | Three battery types | Five battery categories |
| Registration data | Brand and battery type | Additionally chemical composition and tax number |
| Take-back organisation | Take-back schemes for portable batteries | Approved producer responsibility organisations per category |
| Labelling | Mainly national rules | Directly from Regulation (EU) 2023/1542 |
| Sanctions | Tiered fine framework | Up to EUR 100,000, up to EUR 500,000 in severe cases |
Battery law therefore joins a series of product rules that all demand the same thing: robust, structured product data. Anyone who has already modelled the GPSR information duties in the online shop will recognise the pattern - as will readers of our articles on the EU packaging regulation PPWR or the EUDR deforestation regulation. The difference lies in the individual fields, not in the principle.
Who counts as a producer and how retailers slip into that role
The producer definition in the battery regulation is deliberately broad. A producer is anyone who first makes batteries available on the market of a member state on a professional basis - irrespective of the selling technique and expressly including distance selling (EUR-Lex). Batteries already incorporated into appliances are covered as well. A cordless tool set, a wireless mouse with a button cell, an e-scooter or a toy with a battery compartment therefore fall under the same system as a loose cell.
Direct import from third countries
Anyone importing from Asia or the United Kingdom places the goods on the German market for the first time and typically becomes a producer under the act (EUR-Lex).
Goods from other EU states
Sourcing from another member state also establishes the producer role if the battery is thereby made available on the German market for the first time (EUR-Lex).
Private label and white label
Reselling third-party goods under your own brand makes you the producer - a classic case in marketplace and D2C business.
Cross-border direct sales
Distance selling to end users in other member states triggers separate registration duties there; a German entry is not sufficient for those markets.
The second trap lies in pure resale: Section 4 BattDG prohibits retailers from offering batteries from producers who are not registered or not properly registered (gesetze-im-internet.de). The prohibition expressly extends to fulfilment service providers, who may neither store, pack nor ship for such producers (gesetze-im-internet.de). In practice this means the supplier's registration number is a procurement prerequisite rather than a formality - and it belongs in the item master as a verifiable field.
The Stiftung Elektro-Altgeräte Register maintains public registers of registered producers and approved producer responsibility organisations (stiftung ear). In our experience it pays to request the registration number during supplier onboarding, store it in the item master and reconcile it with the register at regular intervals - so a revocation surfaces before it turns into a sales ban across your own range (project experience).
Marketplace business is where things get particularly opaque. Whoever appears as the seller is the contractual partner towards the end customer and shares the information duties - regardless of how the marketplace organises its own checks. How platform and merchant duties overlap is covered in our article on DSA obligations for marketplaces and shops. If you distribute through your own marketplace integrations, include the battery fields in the feed mapping from the start.
Registration, PRO participation and the 15 January 2026 deadline
Under Section 5 BattDG, every producer must register with the brand and the respective battery category before a battery is first made available on the market (gesetze-im-internet.de). The details required follow from Article 55 of Regulation (EU) 2023/1542 (EUR-Lex). Producers without a German establishment must appoint an authorised representative based in Germany (German Environment Agency) - a rule that many European direct sellers noticed late.
- Company name and address including contact details and legal representative
- National identifiers, in particular the commercial register number and the tax number (stiftung ear)
- Battery category and chemical composition per registered brand (stiftung ear)
- Brand names under which the batteries are offered in Germany
- Proof of participation in an approved producer responsibility organisation per category (Section 64(7) BattDG)
The second building block is producer responsibility. Since 1 January 2026, participation in an approved producer responsibility organisation (PRO) has been mandatory - separately for each battery category (IHK). Take-back of waste portable and LMT batteries therefore runs through approved organisations; for starter, industrial and electric vehicle batteries, Sections 18 to 22 BattDG set out separate take-back and reporting routes (gesetze-im-internet.de). Collected waste batteries must be handed over to an organisation, with a commitment period of at least twelve months (gesetze-im-internet.de). In parallel, since 1 January 2026 end users can also hand in e-bike and e-scooter batteries at municipal recycling centres (German Environment Agency).
Without a valid registration the battery may not be offered - neither by the producer nor by the retailer reselling it. If the registration lapses, a de facto sales ban arises for the affected item, which can run through the entire catalogue.
The sanction framework is correspondingly clear: Section 60 BattDG provides for fines of up to EUR 100,000, and up to EUR 500,000 in particularly serious cases (gesetze-im-internet.de). Behind this sits a real volume problem: in 2024, 59,496 tonnes of portable batteries were placed on the German market and 31,898 tonnes were collected - a collection rate of 53.8 percent (German Environment Agency). European targets rise to 63 percent by the end of 2027 and 73 percent by the end of 2030; for LMT batteries, 51 percent by the end of 2028 and 61 percent by the end of 2031 apply (EUR-Lex). Pressure on collection rates will keep increasing - and with it the scrutiny of retail information duties.
Implementing notice and labelling duties in the shop
For distance selling, Section 24(3) BattDG is the central provision: the information required by Regulation (EU) 2023/1542 and the notices on return options must be provided clearly visible through written and pictorial notices in the media used, placed easy to find on the website, or enclosed with the shipment in writing (gesetze-im-internet.de). A footer link leading to a rarely visited subpage typically does not meet that standard - and certainly not if it only becomes findable after checkout.
- Take-back notice before conclusion of contract - free return of waste batteries, visible on the product page and during checkout
- Notice of the end user's return obligation, at least in German
- Crossed-out wheeled bin symbol as a pictorial notice, not as plain running text
- Chemical symbols Pb, Cd or Hg where the relevant heavy metal content applies
- Battery category, chemistry and weight as machine-readable product details
- Deposit notice for starter batteries including the refund route
The regulation's labelling stages apply in parallel. The symbols for lead and cadmium have applied since 18 February 2024, the crossed-out wheeled bin since 18 August 2025, general details including capacity and minimum average duration follow on 18 August 2026, and the QR code with extended information on 18 February 2027 (IHK). CE marking has been mandatory for newly placed batteries since 18 August 2024 (IHK). For the shop this means: the data fields that merely mirror labelling in 2026 become the entry point to the battery passport in 2027.
| Date | Duty under the regulation | Impact in the shop |
|---|---|---|
| 18 Feb 2024 | Symbols for lead and cadmium | Heavy metal symbol as a product attribute |
| 18 Aug 2024 | CE marking of newly placed batteries | Conformity evidence in the supplier dossier |
| 18 Aug 2025 | Crossed-out wheeled bin symbol | Pictorial notice on product and checkout pages |
| 18 Aug 2026 | General details, capacity, minimum duration | New mandatory fields in the product record |
| 18 Feb 2027 | QR code on every battery, passport for selected categories | Linking product data with passport data |
The wheeled bin symbol is often embedded as a plain image - without alternative text the notice is not perceivable for screen readers. If you are working on accessible design under the European Accessibility Act anyway, deliver mandatory symbols as labelled graphics with meaningful alternative text and additionally show the wording as plain text next to the symbol.
Maintaining mandatory details via attribute sets instead of copy-paste
The most common implementation mistake is also the most convenient one: the mandatory details are copied into the product description. That works until the first catalogue import, the first feed export or the first change in the law. After that the legal text sits in thousands of descriptions in slightly diverging variants, is neither filterable nor verifiable, and disappears with the supplier's next text update.
Legal text living in a product description field does not survive a catalogue change. Mandatory details belong in fields, not in running text.
XICTRON e-commerce team
Structure
Every mandatory detail gets its own typed field - select lists for category and chemistry, numeric fields for weight and capacity, switches for removability and deposit liability.
Validation
As soon as the contains battery flag is set, dependent fields become mandatory. Imports without those values end up in an error list instead of the live catalogue.
Output
Product page, order confirmation, data sheet PDF and marketplace feed read the same source. A change to the text template takes effect across all channels.
Where a PIM system is already in place, the attribute set belongs there and is handed over to the shop; without a PIM, the shop takes the leading role. What matters is that there is one source. For businesses with a connected ERP, it is worth tracing where the data originates: category and chemistry usually come from the supplier data sheet, the registration number from the supplier master, the battery weight from the technical data sheet. Bringing those three sources together cleanly is the actual project effort - not rendering the notice text.
An attribute model for Shopware: a concrete proposal
In Shopware, the model can be built as a dedicated custom field set bound to the product entity. The proposal below covers the details actually needed in the shop - for display, filtering, feed export and internal checks. The names deliberately carry a prefix so that they remain collision-free during updates and plugin installations.
{
"name": "xic_battery_law",
"config": { "label": { "en-GB": "Battery law", "de-DE": "Batterierecht" } },
"relations": [{ "entityName": "product" }],
"customFields": [
{ "name": "xic_batt_included", "type": "bool" },
{ "name": "xic_batt_category", "type": "select",
"options": ["portable", "lmt", "starter",
"industrial", "ev"] },
{ "name": "xic_batt_chemistry", "type": "select",
"options": ["li_ion", "ni_mh", "alkaline", "lead_acid", "other"] },
{ "name": "xic_batt_weight_g", "type": "float" },
{ "name": "xic_batt_capacity_wh", "type": "float" },
{ "name": "xic_batt_removable", "type": "bool" },
{ "name": "xic_batt_symbol", "type": "select",
"options": ["none", "pb", "cd", "hg"] },
{ "name": "xic_batt_deposit", "type": "bool" },
{ "name": "xic_batt_producer_regno","type": "text" },
{ "name": "xic_batt_pro_scheme", "type": "text" }
]
}- Switch first:
xic_batt_includeddrives the entire logic - if it is not set, all further fields stay hidden. - Variants inherit: the set is maintained on the parent product and inherited by variants; deviating battery sizes are overridden selectively.
- Validate imports: the product import checks category, chemistry and weight for completeness and writes violations to an error log instead of accepting them silently.
- Keep texts central: the rendered notice text lives in the snippets, not in the product record - so it stays multilingual and maintainable in one place.
- Map feeds: category, chemistry and weight are added to the export profiles for marketplaces and price portals.
Output happens through a dedicated storefront block on the product detail page and during checkout. Because that block renders on every product page, it should be built cache-friendly - how to separate caching and personalised content cleanly is described in our article on the Shopware cache rework for logged-in customers. For the initial population of large catalogues, asynchronous processing is the sensible route; what to watch for in day-to-day operations is covered in the article on message queue workers in production.
A small report listing all active items with the battery flag set and incomplete mandatory fields replaces manual spot checks. In projects it has proven useful to run this report weekly and additionally evaluate it before every larger catalogue import (project experience).
Take-back, returns and labels in the order process
Under Section 14 BattDG, retailers must take back waste portable and LMT batteries free of charge - limited to the categories they carry or have carried, and to household quantities (gesetze-im-internet.de). In distance selling, the in-store take-back is replaced by the duty to provide suitable return options within a reasonable distance of the end user (gesetze-im-internet.de). The act does not define reasonable conclusively; in practice it comes down to a combination of a return shipment option and guidance towards nearby collection points.
- Notice before conclusion of contract: take-back information on the product page and in the cart, not only in the order confirmation.
- Confirmation email and delivery note: the notice text is pulled from the same snippet and enclosed with the shipment.
- Return form in the customer account: customers request a take-back label; battery category and quantity are recorded in the process.
- Label and shipping guidance: the label is provided together with the transport requirements for lithium batteries.
- Document goods receipt: returns are recorded per category and handed over to the producer responsibility organisation.
- Report quantities: recorded quantities feed into the periodic reports and are stored in an audit-proof way.
The documentation aspect is regularly underestimated. Because take-back volumes have to be tracked per category and passed on, a paper form becomes impractical over time. A small data record per take-back event - category, estimated weight, date, receiving organisation - that can be exported is the more sustainable option. If you are digitising returns processes anyway, battery take-back can be added as its own process type with manageable effort (project experience).
A clearly communicated return route reduces customer service enquiries and supports the credibility of sustainability claims. With a collection rate of 53.8 percent (German Environment Agency), a working return process is also a visible differentiator in the market.
Starter batteries: handling the deposit in distance selling
Starter batteries follow their own mechanics: Section 19 BattDG obliges retailers to charge a deposit of EUR 7.50 including VAT where the buyer does not hand in an old starter battery at the time of purchase (gesetze-im-internet.de). In distance selling the deposit must be refunded when the customer presents a written or electronic proof of return that is no more than two weeks old at the time of presentation (gesetze-im-internet.de). Batteries already installed in vehicles are exempt from the deposit duty.
- Show the deposit as a separate line item in the cart rather than folding it into the product price
- Automatic assignment through the
xic_batt_depositfield instead of manual maintenance per item - Refund process mapped in the customer account, including upload of the proof of return
- Deadline logic for the two-week window checked technically so that refunds remain traceable
- Accounting integration so that deposit collection and refund are reflected correctly on documents
Deposit amounts must be clearly recognisable and correctly disclosed to customers. If you display prices, surcharges and discounts in the shop, keep price indication rules in mind - our article on strikethrough prices and discount advertising provides the context.
Outlook: the battery passport from February 2027
From 18 February 2027, the digital battery passport becomes mandatory for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries; it is reached through the QR code that every battery placed on the EU market must carry from the same date (IHK). For portable batteries, the QR code leads to the mandatory labelling information rather than to a full passport. What a digital product passport is in general and how it fits into the European ecodesign framework is covered in our article on the Digital Product Passport - this piece is about shop-side preparation.
Two further dates belong on the plan: from 18 February 2027, portable batteries must be removable and replaceable by end users, and replacement batteries have to remain available for at least five years (IHK). And the supply chain due diligence obligations under Article 48 of the regulation have been postponed by two years to 18 August 2027; they apply to companies with an annual turnover above EUR 40 million (EUR-Lex). For smaller retailers, the supplier's data handover therefore remains the relevant lever.
- Provide unique identifiers per item and batch, not just the article number
- Carry batch and serial numbers from the ERP into the shop where they are customer-relevant
- Set up fields for capacity, chemistry and weight today so that passport data can dock onto them
- Request supplier data in structured form instead of as PDF attachments, so details can be ingested automatically
- Plan the spare part and replacement battery range to serve the availability duty from 2027
- Define responsibilities for who maintains, checks and corrects passport data
Checklist: battery law in the online shop
- Range reviewed: which items contain batteries or are batteries?
- Battery category determined per item and stored in the product record
- Own producer role assessed - direct import, private label, cross-border direct sales
- Registration with the Stiftung Elektro-Altgeräte Register up to date, including chemical composition and tax number
- Participation in an approved producer responsibility organisation evidenced per category
- Supplier registration numbers captured in the item master and reconciled regularly
- Take-back notice visible before conclusion of contract on the product page and in checkout
- Wheeled bin symbol and chemical symbols rendered as structured details
- Return process with label, recording and quantity reporting documented
- Deposit logic for starter batteries including the refund route implemented
- Data fields for the QR code and battery passport from 2027 prepared conceptually
This article draws on Regulation (EU) 2023/1542 concerning batteries and waste batteries as published on EUR-Lex, the German Battery Law Implementation Act (BattDG) as published on gesetze-im-internet.de, publications by the Stiftung Elektro-Altgeräte Register, data and notices from the German Environment Agency, and guidance leaflets from the German Chambers of Industry and Commerce (IHK) on the new battery law. Figures and deadlines quoted may change over time. This article does not constitute legal advice. Status: August 2026.
As a rule, yes. The battery regulation expressly covers batteries incorporated into appliances (EUR-Lex). Anyone selling tools, electronics or toys with a battery typically falls into the same set of duties as a seller of loose cells.
In our experience, yes. A producer under the regulation is anyone who first makes batteries available on the market of a member state on a professional basis - irrespective of the selling technique and including distance selling (EUR-Lex). Direct import from a third country or from another EU state typically establishes that role.
Affected registrations are deemed revoked retroactively as of 1 January 2026 (Section 64(7) BattDG). Without a valid registration, the batteries may neither be offered by the producer nor resold by retailers under Section 4 BattDG; re-registering with complete details is then the usual route.
Typically not. Section 24(3) BattDG requires clearly visible written and pictorial notices in the media used, easy-to-find placement on the website, or written enclosure with the shipment (gesetze-im-internet.de). Rendering the notice on the product page and during checkout is the safer route.
Yes, in principle. Section 14 BattDG obliges retailers to take back waste portable and LMT batteries of the categories they carry or have carried free of charge; in distance selling, suitable return options within a reasonable distance must be provided (gesetze-im-internet.de). Scope and design depend on the product range.
For LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, the battery passport applies from 18 February 2027 (IHK). For all other ranges it is worth preparing the data model - the fundamentals are explained in our article on the Digital Product Passport.
Treating product compliance as a data task
Battery law is not an isolated topic but the next building block in a series of rules that all need the same foundation: structured, verifiable product data. Anyone who holds category, chemistry, weight and registration number as fields rather than as running text not only meets the information duties but also creates the basis for filters, feeds and the battery passport from 2027. XICTRON implements mandatory details, attribute models and take-back workflows technically in the shop - from the field structure and storefront output through to the connection with ERP systems and marketplaces. Talk to us about a review of your product range or have the implementation planned as part of a technical consultation.