The Plain & Simple BATT & “BattG” Compliance Scheme

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THE PROBLEM

What’s BATT?

The European Battery Directive 2006/66/EC [BATT] governs the putting on the market of batteries and accumulators, the limitation of dangerous substances in those, and the take-back and recovery of old batteries and accumulators. It serves as the basis for the national transposition of the different requirements in the member states of the EU. Due to dependencies of national recovery structures there is no pan-European implementation of the Battery Directive. Instead, each member state has its own national legislation, requiring an individual Compliance solution per country.

What’s the “BattG”?

he “Batteriegesetz” [“BattG”] is the German transposition of the BATT Directive. Extensive requirements and obligations apply, not only for producers and other organizations putting batteries on the market but also resellers. Following the underlying “Polluter Pays Principle” also the recycling costs have to be covered. The “Umweltbundesamt” [UBA] as the official Clearing House has established a register for battery producers and importers. Without registration, no new batteries or accumulators may be put on the German market.

Who needs to act?

  • Producers: German manufacturers of batteries & accumulators,
  • Importers: Resellers importing batteries & accumulators into Germany and putting them onto the market for the first time,
  • Dealers: Resellers of batteries and accumulators (information and take-back obligations); Resellers that offer noncompliant batteries & accumulators produced by third parties become “producers” (“Reseller Rule”).

Which Products are BATT-relevant?

What’s to do?

Producers, importers, and resellers need to provide the Compliance of the batteries along the following three categories, before they may be offered and sold in Germany:

No Compliance – No Market!

Which fines and sanctions exist?

  • Legal complaints by competitors or other third parties
  • Fines of up to EUR 100000 per individual case
  • Sales ban until the products are compliant
  • Recall of the noncompliant products
  • Skimming of the profits for historical sales
  • Spreading of the risk of the above mentioned sanctions to all resellers which offer or sell noncompliant products [reseller rule]

THE SOLUTION

Ex-BATT® – Our one-stop BATT solution

The complexity of the German “Batteriegesetz” makes BATT compliance in Germany a significant challenge for producers and other affected companies. An own solution has to satisfy a wide range of requirements and obligations. Normally, there are several different contacts, suppliers, and cost centers involved, resulting in high efforts and costs. Also, errors during the implementation of the BATT compliance and also the dynamics of the underlying regulations pose a high risk for all involved parties. Ex-BATT® provides a one-stop solution for all requirements and obligations resulting from the German “Batteriegesetz”:

FAQ

The company that is putting new batteries or accumulators on the German market for the first time, e.g. by offering it for sale, renting it, or as a giveaway. Resellers offering unregistered products may be punished like producers. We will gladly register you! Please contact us.
As soon as new batteries under the scope of the Battery Law is put on the German market they need to be registered.
No, each company needs to register its own brands and battery types, even if other producers already registered for the same brand and battery type.

Yes. It’ll not suffice to just receive the “BattG-Melderegisternummer” (registration number in the German battery register) for one single brand, if batteries with additional brands are put on the market.

If the brand on the battery is invisible without disassembling the device or unknown the brand mark on the electrical equipment will usually suffice.
You will have to provide a take-back solution (like Ex-BATT®) for old batteries.
For automotive batteries, a deposit needs to charged. Furthermore, there are bans and thresholds for certain hazardous substances. Also, batteries need to be labelled.
No! Depending on the sales channels into the other countries you may be required to provide separate BATT compliance solutions there. By the way: This also applies for non-EU countries like Switzerland or Norway. Contact us to learn more about your individual requirements.

CONTACT

Please contact us

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