09 December 2020

Germany: BattG2 to enter into force 01.01.2021

The new batteries act stipulates that there will no longer be a privileged GRS in future - but only producer-owned take-back systems. This is intended to promote competition. In addition, the annual collection quota for waste portable batteries will be increased from currently 45% to 50%.

Further, a uniform responsibility for the registration of producers and the revocation of registration as well as for the approval and the revocation of the approval of producers' own take-back systems at the Stiftung elektro-altgeräte register (Stiftung-ear) is established.

The existing obligation of producers to notify the German Environment Agency (Umweltbundesamt) about placing batteries on the market will be extended to a fee-based registration with the Stiftung-ear (comparable to the requirements of the ElektroG). The applied for registration will only be granted if all requirements are met.

Producers that already reported the placing of batteries on the market according to the previous legal requirements to the German Environment Agency, must be registered at Stiftung-ear by 1st January 2022 at the latest. Please note that producers will only benefit from this transitional period if there are no changes of the statements made towards the German Environment Agency. Should for example the brand or type of battery or the company data have changed, the obligation to register will be effective directly on the new BattG coming into force. Therefore, we highly recommend that producers check their existing registration for its topicality and correctness before the end of this year and, in the event of discrepancies, to report this to the German Environment Agency.

New producers who need a registration from 1st January 2021 on, should definitely register with the German Environment Agency before. It will only be possible to apply for registrations with Stiftung-ear from 1st January 2021 on.