Battery types and categories in the Battery Act

Definitions under the Battery Act (BattG)

• Battery: A source of electrical energy generated by chemical conversion, consisting of primary cells (non-rechargeable) or secondary cells (rechargeable, accumulators).
• Battery pack: A group of batteries, connected or housed together, that the end user cannot separate.
• Primary batteries: Non-rechargeable, e.g. alkaline-manganese batteries in remote controls.
• Secondary batteries (accumulators): Rechargeable, e.g. lithium-ion batteries in smartphones.
• Manufacturer: Any party that first places batteries on the German market, including importers.

Battery Types under the Battery Act (BattG)

The BattG distinguishes three types of batteries, defined by usage and take-back obligations. The classification follows a priority order: first vehicle battery, then industrial battery, and finally portable battery (BattG § 2 (6) Sentence 2). Batteries weighing over 1 kg are presumed to be industrial batteries in case of doubt.

Vehicle Batteries

Used for starting, lighting, or ignition (SLI) in vehicles that operate independently of railways (e.g. cars, not trains). Commonly lead-acid batteries like VRLA or AGM types.

• Examples: car starter batteries, lighting batteries in vehicles

Manufacturers must accept used batteries free of charge from retailers and treatment facilities (BattG § 8). Retailers pass them to manufacturers without setting up collection points. A deposit of €7.50 (incl. VAT) applies to individual deliveries and is refunded upon return (BattG § 10).

Industrial Batteries

Used for industrial, commercial, or agricultural applications or for powering electric or hybrid vehicles. Always rechargeable, often based on lithium, lead, or nickel.

• Examples: e-bike batteries, batteries in electric vehicles, UPS batteries, batteries in agricultural machinery

Manufacturers must offer free return options for retailers and treatment facilities (BattG § 8). Recyclers report annually to the German Environment Agency (UBA) (BattG § 15 (3)).

Portable Batteries

Encapsulated batteries that can be handheld, including button cells, even when used commercially. Power portable or permanently installed devices.

• Examples: AA batteries, watch button cells, rechargeable smartphone/laptop/toothbrush batteries, smoke detector batteries

Manufacturers must join a take-back system (BattG §§ 5, 7). Retailers must accept portable batteries free of charge, often via collection boxes in supermarkets or electronics stores (BattG § 9). The minimum collection rate is 50% (BattG § 7a).

Exemptions from the BattG:

• Batteries used for national defense (e.g. in military equipment)

• Batteries in equipment for space applications

• Batteries in devices excluded from ElektroG, provided they only function in those devices

New Battery Categories from August 2025 (BattDG)

The Battery Law Implementation Act (BattDG) will come into effect in August 2025, implementing EU Regulation 2023/1542 (EU Battery Regulation). It introduces five new battery categories to replace the previous three:

• Portable batteries: Encapsulated, handheld (e.g. AA batteries, smartphone batteries)

• Light vehicle (LV) batteries: For light transport (e.g. e-bikes, e-scooters)

• Starting batteries: For vehicle starting, lighting, and ignition (equivalent to former vehicle batteries)

• Industrial batteries: For industrial or commercial purposes, excluding EV propulsion

• Electric vehicle batteries: For propulsion of electric vehicles (e.g. e-cars)

Good to Know: Battery Types by Chemistry

Batteries are vital for modern technology, from smartphones to electric cars, but their disposal is complex due to pollutants like lead, cadmium, or lithium. The Battery Act (BattG) enforces strict take-back and recycling regulations that vary by battery type and chemical composition.

The chemical makeup influences their applications: lead-acid batteries are typical in vehicle starters, while lithium-ion batteries dominate in electric vehicles, smartphones, and laptops. From August 2024, portable batteries may contain no more than 0.01% lead, effectively banning lead-based portable batteries and forcing manufacturers to use alternative materials (EU BattV, Annex I). While this change will simplify recycling, it may increase production costs.