In this newsletter, we inform you regularly about current developments in the field of environmental compliance.
If you have any questions, our experts will be happy to provide you with personal advice at any time.
Today's topics at a glance
Germany: New draft bill of the BattDG
EU: New reparability index for smartphones and tablets from June 2025
EU: Postponement of the start of due diligence obligations for batteries
EU: Simplification of ESG reporting obligations
USA: New EPR law in Washington
Germany: Advice on the communication of the Stiftung ear
Webinar invitation: EU Battery Regulation
We wish you an exciting read and look forward to your feedback!
Yours sincerely German Recycling
Germany: New draft bill of the BattDG
The draft bill was published on May 27, 2025 and still has to go through the Bundestag and the Bundesrat.
The short-term publication was necessary as the draft already existed, but the legislative process had to be restarted due to the change of government.
The law must come into force on 18.08.2025, as the regulations applicable until then (Battery Directive 2006/66/EC ) no longer apply and the previous BattG does not take the new Regulation (EU) 2023/1542 into account.
The most important changes to the draft law and the current publication:
The 3 battery types become 5 battery categories (portable batteries, LV batteries, starter batteries, electric vehicle batteries, industrial batteries)
Extended take-back obligation: In future, all battery categories will be subject to the obligation of an area-wide take-back solution (connection to an organization for producer responsibility (OfH) or equivalent self-take-back solution)
the chemical composition of the batteries and the tax ID must be stated
Obligation of municipal recycling centers. From the effective date, these are also obliged to accept LV batteries from e-scooters and e-bikes.
Fictitious registration:From the date of application with all the necessary information for battery registration, the application should now be considered approved after a period of 12 weeks if it has not been processed and approved by then.
Implementation in the institutions is also being driven forward. The ear foundation has not yet indicated that there will be any changes to the timetable for the introduction of the new procedures.
The deadline for implementation will remain 18.08.2025.
If you have any questions, our team will be happy to help you at any time.
EU: New reparability index for smartphones and tablets from June 2025
From June 20, 2025, smartphones and tablets will be the first product group to receive a reparability index on the EU energy label.
What is the repairability index?
The repairability index rates the repairability of appliances on a scale from A (very repairable) to E (poorly repairable). Among other things, it evaluates
Depth of disassembly - How easy is it to open an appliance without damaging it?
Availability of repair information - Do specialist companies have access to the necessary instructions and diagnostic tools?
Further information on the EU energy label
In addition to the repairability index, the new label for smartphones and tablets also includes
Battery life per charge cycle
Reliability class after several drop tests
Battery life in cycles up to 80% remaining capacity
Protection against moisture and dust (IP protection class)
Who is affected?
Manufacturers & distributors:
Must provide technical information and repair data
Must design their products in such a way that classification is possible
Must label products with the new energy label
Retailers (stationary & online):
Must display the new energy label clearly at the point of sale or on the product page
Must not offer products without the correct label (not even old stock!)
EU: Postponement of the start of due diligence obligations for batteries
With the proposal COM(2025) 258 final, the EU Commission wants to postpone the start date for central due diligence obligations from the EU Battery Regulation (2023/1542) by two years - from originally 18.08.2025 to 18.08.2027. The aim is to create more preparation time for companies and authorities.
Affected obligations:
Supply chain & raw material procurement: Documentation and compliance with ESG requirements for primary raw materials
Third-party verification by notified bodies: These have only been designated in around half of the EU Member States to date
Conformity assessment and documentation: a prerequisite for third-party verification
Guidelines on interpretation: also postponed until 26.07.2026 in order to harmonize them with the CSDDD guidelines
Simplifications in the proposal:
Threshold increase: only companies with a turnover > € 150 million (previously € 40 million) are affected
Reporting obligation only every 3 years instead of annually
No suspension of EPR obligations
Important for manufacturers, importers and dealers:
The EPR requirements from the Battery Ordinance will apply unchanged from 18.08.2025.
In concrete terms, this means
Obligation to appoint an authorized representative for foreign manufacturers
Extension of the battery categories (industrial, LMT, EV batteries)
Labeling obligations
Digital product passport
Gradual introduction of CO₂ footprint certificates
Expansion of take-back and information obligations
The draft bill for the Battery Implementation Act has been published and specifies the national requirements.
While simplifications and deadline extensions are in sight for due diligence obligations, EPR implementation remains on track.
Still unsure? We can advise you individually on the interpretation and implementation of your EPR obligations.
With the Omnibus Regulation, the EU Commission has presented two proposals to simplify sustainability reporting (ESG). The aim is to reduce bureaucracy, ease the burden on companies and make ESG reports more practical.
The procedures at a glance
COM (2025) 80 - Short-term measure: Temporary suspension of the CSRD timetable ("wave 2") Adopted by the EU Parliament on April 3, 2025
COM (2025) 81 - Medium-term reform: Comprehensive changes to CSRD, EU taxonomy and CSDDD Implementation expected from October 2025 at the earliest
Changes to the CSR
User group reduced: Only companies with >1,000 employees and >€50 million turnover or >€25 million balance sheet total
Reporting obligation for "wave 2" postponed: First report for financial year 2027 (reporting year 2028)
Capital market-oriented SMEs excluded
Large companies may not request additional ESG data from SMEs, except in justified exceptional cases
Introduction of voluntary VSME reporting standards for smaller companies
Sector-specific standards to be dropped completely
ESRS Set 1 is being revised: EFRAG to submit proposal for reduced data points by October 31, 2025
Limited assurance review remains, but "reasonable assurance" no longer provided
Changes to the EU taxonomy
Application threshold increases: New threshold: >1,000 employees and >€450 million turnover
More flexible reporting obligations: Introduction of materiality thresholds - small activities can be treated in a simplified manner
Changes to the EU Supply Chain Directive (CSDDD)
Start of application postponed to July 26, 2028
Focus on direct business partners instead of the entire value chain
Monitoring obligation only every 5 years (instead of annually)
Climate transition plans must be included but not implemented
No civil liability, no EU-wide sanctions
Financial sector excluded
Are you unsure whether your company is affected by the planned changes? We will be happy to help you assess the impact of the Omnibus Regulation on your reporting obligations - individually, practically and with legal certainty.
With the E2SSB 5284 law, the US state of Washington is introducing a new EPR (Extended Producer Responsibility) system for packaging and paper products (PPP) from July 2026. The aim is to improve the stagnating recycling level and make manufacturers more responsible.
Who is affected?
All businesses that distribute packaging or paper products for non-commercial use in Washington - including:
Manufacturers (as defined by the law) - including:
Brand owners
Companies that import or ship products into the state
Online retailers who sell products directly to end customers in Washington, even if they are based outside the USA
Which products are affected?
Packaging made of paper, plastic, glass or metal (e.g. outer packaging, shipping materials)
Paper products such as flyers, brochures, magazines
(exceptions apply, for example, to books, construction paper and newspapers with small print runs)
What needs to be done?
By July 1, 2026:
➤ Join a Producer Responsibility Organization (PRO) or register individually
➤ Check whether you are considered a "producer"
➤ Check packaging & print products for recyclability
Attention: Penalties for violations
1,000 $ per day and violation, up to 10,000 $ if repeated
Further penalties for continued distribution of non-compliant products
Overview: EPR in Washington State
Washington State has enacted several extended producer responsibility (EPR) and product stewardship laws. These programs are aimed at strengthening the responsibility of distributors for the entire life cycle of their products
Currently implemented EPR programs apply to:
Electronic equipment
Mercury-containing light sources
Photovoltaic modules (solar panels)
Pharmaceuticals
paints
batteries
If you have any questions about the EPR obligation for packaging or other product groups in the USA or require support, our experts can also advise you on country-specific special regulations such as those in Washington State.
Germany: Advice on the communication from the Stiftung ear
At the beginning of June, some manufacturers were asked directly by the ear foundation to submit a quantity report by email, even though an authorized representative for the quantity report is registered with ear. This also affected some of our customers.
These messages were sent in error and are due to a technical problem at the ear foundation.
Communication regarding the quantity report is exclusively via us as your authorized representative or service provider. We will of course continue to send your reports correctly and punctually as usual.
There is therefore no need for you to take any action. Should you still have any questions, our team will be happy to help you at any time
To ensure that you continue to receive an informative and appealing newsletter in the future, we look forward to your feedback. Feel free to send us an e-mail and let us know your opinion, comments and suggestions for topics.
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