Ramblings on German battery law

Germany has laws for everything, including batteries (Batteriegesetz).

In order to be able to e.g. import products with batteries from outside the EU and sell them inside Germany (or the EU), you need to be registered as a battery manufacturer/importer. You also need to become member of one of the registered/accredited companies that take care of recycling the batteries (i.e. put small boxes in supermarkets where people can put their old batteries).

What's funny is that there is absolutely no lower boundary for that for small businesses. What that means for my company: I need to pay 1 Eurocent for each LiIon powered mobile phone to that recycling company.

I guess at current estimated volume, we will have to pay something like 1 to 2 EUR every year. The recycling company won't even send us an invoice if the amount is < 20 EUR total.

So all this comes down is an exercise in buerocracy. We need to send a monthly report on the quantities every month, and there's a hard deadline that needs to be followed.

Furthermore, we need to put fancy stickers on each of the battery, covering at least 3% of the battery surface. That means opening every box, removing the battery from packaging, putting the sticker on it and re-packaging the box. Modern batteries normally have the symbol printed by the manufacturer, but we're talking about Motorola C1xx phones that have been produced from 2005 to 2008 here.

I certainly don't object to manufacturers or importers having to pay for the recycling. But if recycling is actually that cheap, and we're talking about single-digit EUR amounts per year, the administrative overhead (time needed for making the monthly reports, putting stickers on the batteries, etc) costs something like 100 times the actual recycling cost. Is that really worth it? Why not have a lower threshold for small businesses?