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What is the difference between the new BattG2 and old German battery law BattG?

We believe that many sellers have encountered the battery law BattG audit when selling on the German e-commerce platform such as Amazon Germany. In the past, usually WEEE  was firstly checked, then secondly the battery law BattG.  But in the future, Amazon may vigorously check this new German battery law BattG2. Because from January 1, 2021, BattG has been upgraded to a new version:  the battery law BattG2.

What’s new about the new German battery law BattG2?

The old battery law BattG is governed in this way:

1. Only need to register with UBA, the German Federal Environment Agency.

2. No approval or review of the information provided by the manufacturer.

3. The German states are responsible for the approval of recyclers.

The new battery law BattG2 is governed in this way:

1. Starting from January 1, 2021, all registration applications will be handled uniformly through the German EAR official.

2. Under the new BattG2, Stiftung EAR, an existing joint agency under the German Electric Law, will take over the following tasks from the competent authority, the Federal Environment Agency (UBA) through sovereign loans:

  • Determine the responsibilities of the manufacturer and the responsibilities of classifying batteries or electrical and electronic equipment containing batteries
  • Inspection and confirmation by the authorized representative designated by the manufacturer
  • Inspect, issue and cancel the manufacturer’s registration
  • Disclosure of the operation of the manufacturer’s register
  • Review, approve and revoke the approval of the portable battery recycling system
  • In charge of recovery system that controls the collection rate and the recycling rate

To sum up, the new battery law is becoming more and more stringent. Everyone knows that EAR is the supervisory authority of WEEE, and it is also very strict in handling and reviewing. Now it is necessary to review the battery law BattG2, which will cause a delay in the time for certification.

Is there a transition period?

Generally, there is a transition period from the old regulations to the new regulations, and the Battery Law is no exception. Those who have registered with the UBA for the old battery law must re-register with the EAR before January 1, 2022. Those who are not registered should register with the EAR in 2021. 

Which products need to be registered with the new German battery law BattG2?

  • Categories of batteries and accumulators, such as rechargeable batteries, commonly used batteries, etc.
  • Products with built-in batteries, such as smartwatches, mobile phones with built-in batteries, etc.
  • Products containing batteries, electric toys containing batteries, etc.

What are the serious consequences of not registering for the new German battery law BattG2?

  • The ASIN is removed and the product link is removed;
  • When the goods arrive in Germany, they are seized by the customs;
  • Confiscate all profits of the seller in Germany;
  • The maximum fine is 100,000 Euros.

In short, the new battery law is much stricter than before, and sellers should also take more precautions. As a Germany based company and a professional product compliance specialized agent, we are glad to assist you in entering EU market with compliance products.