Industry Groups Raise Concerns Over Potential Battery Sales Ban Due to Regulatory Changes

Several leading industry associations have raised alarms about an impending regulation that could significantly disrupt the sale of batteries in Germany. The upcoming Battery Implementation Act, which is set to take effect in January 2026, introduces new requirements for battery manufacturers and distributors, potentially leading to a de facto halt in the availability of certain battery types on the market.

The associations--the Mechanical Engineering Industry Association (VDMA), the German Electrical and Electronic Manufacturers' Association (ZVEI), and the Association for Information Technology, Telecommunications and New Media (Bitkom)--have expressed concerns over the administrative and logistical challenges posed by the revised legislation. According to these organizations, the strict interpretation of the new law could prevent hundreds of thousands of batteries from entering the market. These batteries are essential for a wide range of applications, including medical equipment, material handling vehicles such as forklifts, and everyday household and entertainment technology.

The central issue arises from the new requirement that only manufacturers registered with an officially recognized Producer Responsibility Organization (OfH) will be allowed to sell batteries. Currently, only one such organization has been approved to manage the collection and recycling of used batteries. The approval process, overseen by the Foundation for the Register of Old Electrical Appliances (EAR), now demands significant financial securities from organizations seeking recognition--a stipulation that has not previously been enforced at this scale.

Industry representatives argue that the existence of a single approved Producer Responsibility Organization is insufficient to accommodate all manufacturers before the January deadline. Many producers are facing challenges registering in time, creating a bottleneck in the system. Without additional approved organizations or an extension of the compliance deadline, the industry fears widespread disruptions in the supply of batteries to the market.

The associations are therefore calling for a temporary suspension--referred to as a moratorium--of the new regulations. They maintain that, without a practical framework enabling all manufacturers to comply, the objectives of the law cannot be fulfilled. The lack of adequate infrastructure, they argue, undermines efforts to improve battery recycling and environmental stewardship, potentially leading to shortages of critical products across sectors.

The situation is particularly pressing given the importance of batteries in modern society. In the medical field, batteries are integral to the operation of life-saving equipment. In logistics and industry, they power vehicles and machinery critical to supply chains. In households, batteries are found in everything from kitchen appliances to personal electronics. Any interruption to the supply chain could have far-reaching implications.

Authorities have not yet responded to the calls for a moratorium or provided information on whether additional Producer Responsibility Organizations will be approved in time. The industry continues to monitor developments closely, emphasizing the need for a balanced approach that both protects the environment and ensures the continued availability of essential products.

This regulatory shift comes as part of broader European and national efforts to improve the sustainability of battery production and disposal. Enhanced recycling targets and stricter oversight are designed to reduce environmental impacts and encourage manufacturers to take greater responsibility for the entire lifecycle of their products. However, industry groups caution that the pace of regulatory change must be matched by practical implementation measures to avoid unintended consequences for businesses and consumers alike.