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Since 7 October 2025, batteries sold in Germany fall under a new national law, the Batterierecht-Durchführungsgesetz (BattDG), on top of the EU Battery Regulation. This guide covers the duty and import VAT on LiFePO4 batteries from China, who counts as the battery “producer” (Hersteller) in Germany, how registration with stiftung ear and the authorised-representative rule work, and the documents to line up before shipment. Research date: 29 October 2026.
At a Glance (as of 29 October 2026 — verify before shipment)
| Item | Current position | Official source |
|---|---|---|
| Commodity code | 8507 60 00 90 (lithium-ion accumulators, other) | EU TARIC |
| Customs duty (third country, incl. China) | 2.7% | EU Common Customs Tariff (R1006/11), shown in the UK XI tariff service |
| Import VAT (Einfuhrumsatzsteuer) | 19% standard rate; 0% for qualifying home PV storage | § 12(1) and § 12(3) UStG |
| Producer registration | Register with stiftung ear by brand and battery category before first making batteries available in Germany | § 5 BattDG; stiftung ear |
| Sellers based outside Germany | Must appoint one German authorised representative (Bevollmächtigter), in writing and in German | § 40(2) BattDG |
| Producer responsibility | Join a producer responsibility organisation (OfH) per battery category, or meet the duties individually | § 7(1) BattDG |
| EU layer | Regulation (EU) 2023/1542 applies directly (labels, due diligence, battery passport) | Our EU Battery Regulation guide |
| Transport | UN 38.3 type test; Class 9 dangerous goods (UN3480) | UN Manual of Tests and Criteria; your forwarder |
1. Customs Duty: 2.7% on 8507 60 00 90
Germany applies the EU Common Customs Tariff. For commodity 8507 60 00 90 (lithium-ion accumulators, other), the third-country duty is 2.70% (legal base R1006/11), as shown for the EU tariff in the UK Online Trade Tariff (XI) service. China has no EU trade preference, so China-origin batteries pay this rate. Always confirm the code and any measures for your exact product in EU TARIC before you price a shipment.
Small parcels are treated differently. From 1 July 2026 until 1 July 2028, the tariff shows a customs duty of EUR 3 per item in consignments with an intrinsic value of no more than EUR 150 (footnote TM01066). This matters for e-commerce shipments of small batteries, not for pallet or container imports.
2. Import VAT (Einfuhrumsatzsteuer)
- Rate: “Die Steuer beträgt für jeden steuerpflichtigen Umsatz 19 Prozent der Bemessungsgrundlage” — 19% (§ 12(1) UStG). Imports are a taxable transaction under § 1(1) No. 4 UStG.
- Base: import VAT is measured on the customs value of the goods (§ 11(1) UStG), plus the customs duty and the transport and handling costs up to the first destination in Germany, where not already included (§ 11(3) UStG).
- 0% for home solar storage: § 12(3) UStG sets 0% for the supply and the import of solar modules and “Speicher, die dazu dienen, den mit Solarmodulen erzeugten Strom zu speichern”, where the PV system is installed on or near private homes or certain public-interest buildings. The condition is deemed met at no more than 30 kW (peak) installed gross power in the Marktstammdatenregister. The rate is tied to supply to the PV system operator, so ask your tax adviser before applying 0% to stock you import for resale.
- Deferral: import VAT can be deferred without security where it is fully deductible as input tax (§ 21(3) UStG). VAT-registered importers usually reclaim it.
Worked example (percentages only): on a customs value of €10,000, the duty is €270 (2.7%). Import VAT is then 19% of €10,270 plus any transport costs to the first destination in Germany — at least €1,951.30. Run your own figures in our battery landed-cost calculator.
3. Who Is the Battery “Producer” in Germany?
stiftung ear, the national register, lists who counts as a producer (Hersteller) under battery law (stiftung ear: duties of producers). They include “ein Importeur, der Batterien aus dem Ausland erstmals auf dem deutschen Markt abgibt” — an importer that first makes batteries from abroad available on the German market — and anyone who sells batteries directly to end users in Germany without being established there. That second group “muss einen Bevollmächtigten beauftragen”, i.e. must appoint an authorised representative.
In practice: if your German company imports LiFePO4 batteries from China and sells them on, your company is usually the producer and registers itself. If a seller outside Germany sells directly to German end users, it needs a German authorised representative.
4. Registration with stiftung ear (BattDG)
- Register before first sale: before a producer first makes batteries available in Germany, it — or its authorised representative — must register “mit der Marke und der jeweiligen Batteriekategorie” with the competent authority (§ 5(1) BattDG). Registration is deemed granted twelve weeks after all required information has been submitted, unless the authority objects.
- No registration, no sale: producers may only make batteries available if they are properly registered (§ 4(1) BattDG). If they are not, dealers must not sell the batteries and fulfilment providers must not store, pack or ship them (§ 4(3)).
- Registration number: the registration notice comes with a registration number (Batt-Reg.-Nr. DE). stiftung ear says you must state it “wenn Sie Batterien anbieten oder Rechnungen ausstellen” — when you offer batteries or issue invoices (stiftung ear: applying for battery registration).
- Producer responsibility organisation (OfH): producers must join an OfH for each battery category or carry out their extended producer responsibility individually (§ 7(1) BattDG). In the registration process, stiftung ear asks for the OfH number from your chosen OfH.
- Old registrations: registrations under the former Batteriegesetz (BattG) continued at most until the end of 15 January 2026, and registrations of producers established outside Germany were excluded from that transition (§ 64 BattDG). Re-check any older registration your supply chain relies on.
5. The Authorised Representative (Bevollmächtigter)
Under § 40(2) BattDG, producers without an establishment in Germany “haben einen Bevollmächtigten für die erweiterte Herstellerverantwortung … zu beauftragen”. The representative performs the producer’s obligations in its own name. Each producer may appoint only one, and the appointment must be in writing and in German. stiftung ear adds that one representative covers all of a producer’s brands and battery categories.
For importers buying from LJY Energy, this usually does not apply: the German importer is the producer. It becomes relevant if a non-German company ships batteries directly to German end users.
6. EU Battery Regulation Obligations
BattDG implements the producer-responsibility parts of Regulation (EU) 2023/1542, which also applies directly in Germany: battery categories, CE marking and the EU declaration of conformity, labelling and QR codes, due diligence, carbon footprint rules and the battery passport from February 2027. For the timeline and what it means for LiFePO4, see our EU Battery Regulation guide.
7. Shipping LiFePO4 Batteries to Germany
Lithium-ion batteries ship as Class 9 dangerous goods (UN3480, or UN3481 when packed with or contained in equipment). Every cell and battery type must have passed the UN 38.3 tests in the UN Manual of Tests and Criteria, and your forwarder will ask for the test summary and Safety Data Sheet before booking. Sea freight follows the IMDG Code, road transport within Europe follows ADR, and air freight follows the IATA Dangerous Goods Regulations.
8. Document Checklist
- Commercial invoice and packing list (commodity code 8507 60 00 90, origin, customs value)
- Your EORI number and import VAT arrangement (deferral account or direct payment)
- UN 38.3 test summary for the exact model shipped
- Safety Data Sheet (SDS/MSDS) and dangerous-goods declaration
- stiftung ear registration (Batt-Reg.-Nr. DE) for each brand and battery category, in place before first sale
- OfH participation confirmation for the battery category
- EU declaration of conformity and the labelling data required under Regulation (EU) 2023/1542
See also our LiFePO4 import checklist, certification verification guide and lithium battery import guide. For end-of-life planning, see are LiFePO4 batteries recyclable?
Working with LJY Energy on German Projects
LJY Energy is a China-based LiFePO4 battery supplier and OEM/ODM solutions provider. For German importers we prepare the UN 38.3 test summary and SDS for each order, plus the chemistry, weight and battery-category data you need for stiftung ear registration and OfH reporting. Specifications, pricing, MOQ and lead times are confirmed per project. Request a Germany landed-cost and compliance review with your target product and volume.
Frequently Asked Questions
What is the import duty on lithium-ion batteries from China into Germany?
As of 29 October 2026, the EU third-country duty on commodity 8507 60 00 90 (lithium-ion accumulators, other) is 2.7%. Germany then charges 19% import VAT on the customs value plus duty and transport costs to the first destination in Germany. Confirm the code in EU TARIC before shipment.
Is there 0% VAT on batteries imported into Germany?
Only in specific cases. § 12(3) UStG sets 0% for the supply and import of storage that stores electricity from solar modules, where the PV system is installed on or near private homes or certain public-interest buildings (deemed met at no more than 30 kW peak). Other imports pay 19%. Ask your tax adviser before applying 0%.
Who must register batteries with stiftung ear?
The producer: in practice the company that first makes the batteries available on the German market, including an importer from outside the EU. Registration is per brand and battery category and must be in place before the first sale (§ 5 BattDG).
Does a Chinese supplier need a German authorised representative?
Only if it is the producer without an establishment in Germany, for example when it sells directly to German end users. § 40(2) BattDG then requires one German authorised representative, appointed in writing and in German. When a German company imports and resells, that company is usually the producer.
Does BattDG replace the EU Battery Regulation?
No. Regulation (EU) 2023/1542 applies directly in Germany. BattDG, in force since 7 October 2025, implements its producer-responsibility rules nationally and replaced the former Batteriegesetz (BattG).
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