Since August 2025, the EU Battery Regulation has brought with it new obligations in the context of extended producer responsibility. The new requirements were highlighted and discussed.
On August 18, 2025, the previous EU Battery Directive was finally replaced by the new EU Battery Regulation (BattVO). The new regulations on extended producer responsibility thus came into force. Manufacturers, who can also be producers, importers and distributors, are now obliged to register with the competent authority in each EU member state, join an organization for producer responsibility (OfH) or organize their own take-back and ensure disposal. In Germany, this will be implemented in future via the new Battery Law Implementation Act (BattDG).
To inform the industry about these far-reaching changes, ProduktionNRW organized a virtual information event in cooperation with VDMA Nord on 3 September 2025. A preliminary survey showed that there is still a great deal of uncertainty: over half of the participants were unclear as to whether they should be classified as manufacturers, importers or distributors under the BattVO. The biggest challenges include unclear definitions, missing declarations of conformity, questions about role allocation and the traceability of batteries in complex supply chains.
Fit for the EU Battery Regulation?
Alena Knauz, a consultant for product-related environmental protection at VDMA, presented the key requirements and obligations of the BattVO and explained the consequences for producers, importers and distributors. As soon as a battery is sold in an EU country – whether individually or already installed in a device – it must first be checked who is considered the manufacturer according to the BattVO. As part of extended producer responsibility, manufacturers must be registered in every EU country in which they place batteries on the market for the first time, fulfill take-back and disposal obligations (e.g. via an OfH) and submit regular quantity reports.
In addition to the requirements already in force since 2024 – declaration of conformity, CE marking and symbol for separate collection – the labeling requirements are becoming even stricter. From August 2026, additional information such as capacity, chemical composition and expiration dates must be provided, and from February 2027 there will also be an obligation to label with a QR code. In addition, the due diligence obligations in the supply chain have been postponed to 2027. Specifications on the removability and replaceability of batteries will also apply from 2027, with exceptions for medical or safety-critical devices. In addition, the digital battery passport will be introduced to provide comprehensive information on composition, performance, carbon footprint and supply chains.
Exchange of experience and discussion
The discussion focused on practical questions. One of the topics discussed was how proposals to simplify the BattVO can be incorporated into the current EU consultation on reducing administrative burdens. Other points concerned the definition of the time of commissioning – for example when using button cells in devices – and the associated obligations to provide instructions in all EU languages. The role of rental companies was also discussed and whether they are already considered end customers or only the users of the rented devices.
Further information:
- The EU Battery Regulation can be found here.
- BMUV- Background information on the EU Battery Regulation can be found here.
- The VDMA guide to the Battery Regulation can be found here.
- The VDMA regulatory cockpit can be found here.
Organizer
The event was organized by VDMA Nord in cooperation with ProduktionNRW. ProduktionNRW is the cluster for mechanical engineering and production technology in North Rhine-Westphalia and is organized by VDMA NRW. ProduktionNRW sees itself as a platform for networking, informing and marketing companies, institutions and networks with each other and along the value chain. Significant parts of the services provided by ProduktionNRW are funded by the Ministry of Economic Affairs, Industry, Climate Protection and Energy of the State of North Rhine-Westphalia.