OfH for batteries – what companies need to know now
16. December 2025OfH for batteries – what companies need to know now
16. December 2025EU Battery Regulation (2023/1542) at a glance
Regulation (EU) 2023/154 sets uniform standards across Europe for the entire life cycle of batteries – from raw material extraction, production, and use to collection, recycling, and reuse. It is part of the European Green Deal. The EU Battery Regulation came into effect on February 18, 2024, replacing EU Directive 2006/66/EC. Implementation is taking place in stages.
For Germany: To implement the new regulation, the original Battery Act (BattG) is being replaced by the Battery Law Implementation Act (BattDG).
Objectives of the EU Battery Regulation
The EU Battery Regulation primarily addresses four areas: reducing the environmental impact of batteries, increasing the recycling of battery components, making batteries generally longer-lasting and safer to use, and ensuring greater transparency throughout their entire life cycle. These objectives are being implemented gradually.
In concrete terms, this means, for example:
- Higher collection and recycling rates for used batteries and the setting of minimum values for the recovery of important raw materials such as lithium, cobalt, copper, lead, and nickel.
- Reduction of the carbon footprint and harmful substances.
- More due diligence obligations for the entire supply chain for large companies.
- Transparent information, including through the introduction of clear labeling and the digital battery passport.
- Promotion of battery performance with minimum values.
- Ensuring the interchangeability of device batteries by end users or qualified personnel.
Affected battery categories
The new EU Battery Regulation has expanded the categories. It now applies to: portable batteries, starter batteries, batteries for light vehicles (LV batteries), electric vehicle batteries, and industrial batteries, regardless of size, weight, and integration into the product.
Obligations for different stakeholders
The EU Battery Regulation affects various market stakeholders such as manufacturers, importers, distributors, and recyclers. Below is a breakdown of the most important obligations, some of which have already come into force and others which are still to come.
Obligations for manufacturers
- Registration requirement with the national authority (in Germany: via Stiftung ear)
- Conformity assessment & CE marking
- Technical documentation (safety data, structure, material content))
- CO₂ footprint reports for many types of batteries
- Minimum recycled content (from certain deadlines)
- Establishment of a take-back system or participation in a take-back system (Germany: OfH)
- Supply chain due diligence (postponed to 2027)
- Digital battery passport (2027 → e-bikes, e-scooters, EV batteries, industry >2 kWh)
- Meeting recycling targets
- Reporting to authorities (quantities, collection, recycling rate)
Obligations for importers
The obligations for importers are almost identical to those for manufacturers (see above). They must ensure that products from third countries comply 100% with EU requirements, including registration, labeling, documentation, take-back, recycling, and digital battery passport.
Obligations for retailers
- Free take-back obligation for used batteries of all battery categories (including e-bike batteries). Online, a “reasonable return option” is required.
- Inspection obligation: Only sell batteries that are registered and correctly labeled (CE, symbol, technical data).
- Obligation to inform customers about return options and correct disposal.
- Deposit obligation for starter batteries: Includes collecting deposits, refunding deposits, and documentation.
- Safe handling/storage, especially of lithium batteries (fire protection, hazardous goods regulations).
Recycling companies
- Compliance with recycling efficiency targets
- Compliance with material recovery rates (e.g., cobalt, lithium, nickel)
- Environmental and safety management
- Documentation and reporting to manufacturers or systems
- Proof of recycled content for new batteries
Do you need help fulfilling your obligations?
Interzero will be happy to advise you on all important topics relating to the EU Battery Regulation!
Feel free to contact us by email at sales.epr@interzero.de or by phone at +49 2203 9147-1605!
Key milestones
August 17, 2023 | Formal entry into force of the regulation at EU level. |
February 18, 2024 | Start of application of the EU Battery Regulation in all member states. |
August 18, 2024 | Batteries placed on the market in the EU must meet CE marking, performance, durability, and safety standards. |
February 18, 2025 | The obligation to determine the carbon footprint for electric vehicle batteries comes into effect. |
August 18, 2025 | - The old Directive 2006/66/EC is finally repealed. From this date onwards, the EU Battery Regulation applies throughout the EU as the sole regulation. - Comprehensive obligations regarding the management of used batteries and extended producer responsibility came into force. Manufacturers/online retailers without a registered office in the country of delivery are required to have an authorized representative. |
October 7, 2025 | Entry into force of the revised version of the BattDG. This brings national battery legislation into line with the EU Battery Regulation. |
Planned:
February 18, 2026 | CO₂ footprint requirements will also become mandatory for rechargeable industrial batteries above 2 kWh. |
August 18, 2026 | Certain information regarding capacity and minimum operating time will be required for batteries with specific markings and QR codes. |
February 18, 2027 | - The digital battery passport will become mandatory for rechargeable industrial batteries (>2 kWh) and EV batteries. - Portable batteries must be easy for end users to remove and replace. |
August 18, 2027 | Due diligence obligations in the supply chain become mandatory (for large companies). |
August 18, 2028 | - Minimum values for the shelf life and performance of general-purpose device batteries. - Proof of the minimum proportion of recycled materials in EV and industrial batteries must be provided. |
By the end of 2030 | The collection targets for portable batteries are rising to 73%. |
From 2031 | Stricter targets for minimum proportions of recycled materials in new batteries must be met. |