Manufacturers - Frequently asked questions

Which batteries are subject to reporting obligations?

All portable batteries sold to consumers in Germany. Batteries that are exported are not subject to reporting obligations.

Portable batteries are enclosed batteries that can be held in the hand. Vehicle and industrial batteries are not portable batteries.

The Battery Act (BattG) also differentiates between:

Industrial batteries: batteries used exclusively for industrial, commercial or agricultural purposes and those used in electric vehicles of all kinds and hybrid vehicles. […]

Vehicle batteries: batteries used for starter motors, lighting and ignition in vehicles. […]

 

Who is considered to be a battery manufacturer in the sense of the Battery Act (BattG)?

The manufacturer is the company responsible for the initial commercial sale of batteries in Germany, regardless of the way in which the batteries are sold.

 

What responsibilities do battery manufacturers have?

Any company that sells portable batteries is obliged to collect used batteries from consumers without charge at, or in the immediate vicinity of, the point of sale. The obligation to collect batteries is restricted to used batteries of the type of batteries included, or that were previously included, in the manufacturer’s range.

In addition to return obligations, (Sec. 5 BattG) the Battery Act (BattG) also specifies:

  • Notification obligations – Sec. 4 BattG
  • Performance monitoring – Sec. 15 BattG
  • Collection goals – Sec. 16 BattG
  • Labelling – Sec. 17 BattG
  • Notice obligations – Sec. 18 BattG

 

Which tasks does CCR REBAT handle?

The REBAT battery return system handles all tasks relating to the essential criteria of the Battery Act (Batteriegesetz) on behalf of manufacturers and importers.

They include

  • Registration with the Federal Environment Agency (Umweltbundesamt) according to Sec. 4 BattG
  • The organisation and execution of disposal services
  • The provision of suitable collection containers for used batteries
  • The collection, sorting and recycling of used batteries and the disposal of batteries that cannot be recycled
  • Annual submission of documentation regarding the services performed to the appropriate state authorities according to Sec. 15 BattG (performance monitoring)

 

What duties do mail-order retailers have?

Like every retailer or distributor, mail-order retailers are obliged to accept returned batteries and notify consumers.

Mail-order companies that sell batteries to consumers are required to inform consumers of the following information in the media they use to present their products, or to include written notices with the goods when they are delivered:

  • that batteries can be returned to the point of sale without charge after use,
  • that consumers are legally required to return used batteries and
  • the meaning of the symbol depicting a crossed out dustbin.

Mail-order companies are also obliged to collect used batteries from consumers without charge at, or in the immediate vicinity of, the point of sale. In such cases, the despatching warehouse is considered the point of sale.