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A producer is everyone who places batteries newly on the German market (this therefore includes importers). This also applies to appliances with incorporated or accompanying batteries, irrespective of the trade level at which they are placed on the market. A dealer who deliberately or carelessly distributes batteries from producers who are not registered with the Federal Ministry for the Environment is also automatically deemed to be a producer. The rule of thumb, then, is: whoever writes the first German invoice is a producer within the meaning of the law.

To rule out unfair participation in the market, the law requires that producers take part in a registration process. This means that each producer has to provide details to the Federal Ministry for the Environment of his company, the batteries he has placed on the market and his assurance of collection. Without providing this notification, the producer is prohibited from participating in the market. GRS Batterien assumes the responsibility for providing this notification for all of its contractual partners. The producer only has to sign the contract, fill in the questionnaire and send it back to GRS Batterien. We will do the rest for you.

Everyone placing batteries or appliances on the market in Germany (where these batteries or appliances are being newly placed on the market in Germany) or appliances with incorporated or accompanying batteries for the purpose of sale, consumption or use. If batteries from non-registered producers are distributed, the distributor is automatically deemed to be the producer. This also applies to mail-order operations.

If appliances with incorporated or accompanying batteries are placed on the market, it is sufficient to state the brand of the appliance. This is also the case with button cells. If, for example, watches with incorporated button cells are placed on the market, the watch designation can be stated as the brand.

Yes, the new brand has to be reported straight away. It has to be reported before the batteries are placed on the market. This is very important, otherwise you could incur a fine.

Both for the discontinuation of individual brands and for producers, there is the option of declaring "withdrawal from the market". In such cases, you only have to provide the date of withdrawal of the brand/withdrawal from the market.

Only the producer's intention to participate in the market is to be reported. The quantities placed on the market are reported as usual via GRS Batterien. Quantities are thus not reported to the Federal Ministry for the Environment when registering. The Federal Ministry for the Environment of course receives consolidated data on all quantities placed on the market in the performance review.

The details provided are published on the website of the Federal Ministry for the Environment. A search can be performed to determine easily which producer is placing which brands on the market and by which means he is ensuring collection.

The Federal Ministry for the Environment issues a confirmation of registration as a PDF file, which also contains the registration No. If we carry out the registration for you, we will send you this confirmation promptly including this number. This number should feature prominently, particularly in written correspondence.

Yes. Every producer reports the brands he places on the market. It can, then, be the case that the same brand has to be reported for both portable and industrial batteries as well as for automotive batteries. Moreover, it can be the case that individual brands are placed on the market by several producers.

A distributor who fails to check whether his producer has properly reported his participation in the market in fact "inherits" the characteristics of the producer. Every distributor should definitely check on the website of the Federal Ministry for the Environment whether the batteries or battery-powered appliances he has purchased come from a producer/importer who has reported his participation in the market to the Federal Ministry for the Environment. If he fails to do this and his supplier has not fulfilled his obligations, there can be a fine of up to €50,000.

Depending on the type of battery being placed on the market (portable, industrial or automotive battery), the collection process is different. The collection of portable batteries must be nationwide and comprehensive, covering retail outlets, all public waste management authorities and the treatment facilities for waste equipment in accordance with the Electrical and Electronic Equipment Act. For collection of industrial and automotive batteries, there are tailored solutions available, with collection via the distributor, the commercial end user or recycling by the producer himself. GRS Batterien offers all its contractual partners comprehensive management of waste batteries and guarantees compliance with collection rates (35% by 2012 and 45% by 2016). A new addition to the Batteries Act is the extension to mail-order distributors of the obligation to collect batteries at no charge. In this case, the place of collection is the dispatch warehouse. 

Collected batteries are to be recycled. Recycling must be in terms of component substances. The Batteries Act also stipulates minimum efficiencies for recycling, for example 75% for nickel-cadmium batteries and 65% for lead batteries. The heavy metals in the batteries are to be completely recycled. In a review of performance, producers report their qualitative and quantitative recycling results annually to the environmental ministries at federal state and national level. GRS Batterien not only assumes responsibility for proper recycling on behalf of its contractual partners but also for punctual reporting.

Both producers and distributors have a duty to provide certain information to end users. At the point of sale (in the direct field of vision of the main customer flow), the following information must be provided: that batteries can be returned after use to the point of sale at no cost, that end users (including commercial end users) are legally obliged to return waste batteries, and the meaning of the crossed-out wheeled bin symbol. Mail-order distributors must provide this notification on their website or on the consignment of goods. Furthermore, the producer is obliged to inform the end user of the possible effects of the substances contained in the batteries on the environment and human health as well as of the importance of separate collection and recycling of waste batteries. This information is already provided on the green boxes and containers of GRS Batterien. All that remains is for these to be placed in a prominent, accessible location. The party placing on the market or distributing batteries in electrical or electronic equipment must also inform the user of the type and chemical system of the battery and how to remove the battery safely. Customers can obtain specimen texts for all three duties to inform end users from GRS Batterien on request.

Producers must submit a comprehensive performance review annually. The content of the performance review is specified in the Batteries Act. This includes the volume of batteries placed on the market, the volume of collected and recycled waste batteries placed on the market, the volume of collected and recycled waste batteries and the qualitative and quantitative recycling and disposal results. This information is published. GRS Batterien assumes all responsibilities regarding reporting to the authorities for its contractual partners.

With the coming into force of the Batteries Act, the Electrical and Electronic Equipment Act was also amended. Thus appliances that can be powered wholly or partly with batteries are to be designed in such a way that batteries can be readily removed. The only exceptions are electrical and electronic equipment where, for safety, performance, medical or data integrity reasons, continuity of power supply is necessary and requires a permanent connection between the appliance and the battery.

There are two labelling requirements. First, all batteries must bear the crossed-out wheeled bin symbol. If the battery (for instance a button cell) is too small for this, the symbol can be shown on the packaging. If the limits of 5 ppm for mercury, 20 ppm for cadmium or 40 ppm for lead are exceeded, then the chemical symbol (Hg, Cd or Pb) must appear below the wheeled bin symbol. Please note that the limits for lead for zinc-carbon batteries are usually exceeded and that, since 1 December 2009, distribution of these has been permitted only with the "Pb" under the wheeled bin symbol. The second labelling requirement of the Batteries Act is the provision of capacity information on all portable and automotive batteries. The calculation methods for capacities are still to be specified at EU level. Customers of GRS Batterien will be informed promptly of any changes.