for the new battery law in Germany (as of Jan 2021)

Landbell Group is a highly acknowledged service provider for recycling of batteries. Therefore, we have compiled frequently asked questions and answers concerning the new battery law (01.01.2021) for you.

If you have further questions or need a quotation, feel free to use the contact form below the FAQs.

FAQs & Answers

Where and till when do I have to update my registration?

All batteries valid for registration must be generally registered with the ear-Stiftung from the 01.01.2021 onwards. Manufacturers, who have already registered their batteries via the e-register of the federal environmental agency, need to update their registration with the ear-Stiftung till the 31.12.2021 latest.

What happens when I am registered as a manufacturer and need to change/complement my data within 2021?

From 2021 onwards, you can only change/complement your data via the ear-Stiftung. This also applies to manufacturers, who are still registered with the federal environmental agency in 2021.

Which fees do occur with the registration?

Currently, the registration of batteries with the federal environmental agency is free of charge. However, for the new registration with the ear-Stiftung, there will occur legal fees for the registration. At the moment, there is no final announcement on the legal fees for battery registration yet. We will provide you with the new table of legal fees, as soon as we receive it.

Does a registration have to be refreshed on a regular basis (i.e. yearly)?

The registration of batteries will be valid until you recall it. However, you should regularly monitor your product portfolio to also ensure the registration of new products according to the rules. Changes or complements of your existing registrations must be reported to the ear-Stiftung from the 01.01.2021 onwards.

The brand has already been registered by a manufacturer or supplier. Is another registration necessary?

If batteries have already been registered by your supplier and are already reported as traded on the German market, you do not have to register or report those batteries again. But, please keep in mind that an existing registration of a battery brand does not mean that those batteries are already released from the liability. Therefore, for this, it is crucial, whether your supplier (or their supplier) has reported the put-on market amount in Germany accordingly.

Is a registration without a brand possible?

The brand name of the batteries has to be recorded with the registration. However, if the brand name cannot be determined, you can also use the name of the product, in which the battery is built in.

What happens when I do not register with the ear-Stiftung, but still sell my products in Germany?

In case of infringement, the following applies:

  • Monetary fines up to 100,000EUR
  • Prohibition of sales
  • Skimming of profits

Which batteries are affected by the new battery law?

All batteries are affected by the new law. This also applies for batteries, which are implemented in devices or which are in scope of delivery.

Batteries, which are mandatory to register, are for instance:

  • portable-batteries including button cells, which you can hold capped in one hand. A brand name has to be visible on portable batteries.
  • Industry batteries (among other things also E-Bike-Batteries, E-Scooter-Batteries)
  • Vehicle batteries


  • Powerbanks (counted as batteries, as long as they do not have additional functions. Powerbanks with additional functions may count as electronic device and therefore, fall under the registration obligation of electro devices.)
  • Backup batteries (i.e. in mainboards) count generally as hardware-batteries up to 500g

When I am a manufacturer or the first to put batteries on the market, can I also assign an authorized representative or an authorized third party who takes over my responsibilities?

Yes, independent of whether the office is in another country or whether you have a German subsidiary, you have the opportunity to assign an authorized representative or to authorize another third party.

  • Manufacturer, who do not have a subsidiary within the area of application of this law, can authorize a representative with the obligations after §§4 and 5, §7 Paragraph 1 Phrase 1, §8 as well as §15 Paragraph 3 Phrase 3 and 4.
  • The ones liable to the battery law can assign a third party with the fulfillment of obligations

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