According to the German Electrical and Electronic Equipment Act (ElektroG), any manufacturer or retailer who wants to place electrical and electronic equipment on the market in Germany for the first time is obliged to register with stiftung ear beforehand. Each registration takes place stating the brand and equipment type for the equipment that is to be distributed. If registration is successful, the registered party is assigned a unique WEEE registration number (also WEEE reg. number or WEEE number). Other brands and/or equipment types can then be registered under the same WEEE number.
Definition WEEE number
The WEEE number is a manufacturer number that is assigned to the first distributors of electrical and electronic equipment following successful registration with stiftung ear. It consists of a country code and an 8-digit sequence of digits (e.g. “WEEE Reg. No. DE 12345678”). According to the German Electrical and Electronic Equipment Act, manufacturers must state their WEEE number during product sales and on invoices.
The basis for registration with stiftung ear is the WEEE Directive in force in Europe, which is transposed into German law by the German Electrical and Electronic Equipment Act (ElektroG). The Directive governs the sale, take-back and proper disposal of waste electrical and electronic equipment within the euro area. The abbreviation WEEE stands for Waste Electrical and Electronic Equipment.
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Anyone who trades in products is subject to binding disposal and recycling duties, non-compliance with which can lead to considerable sanctions and warnings
The problem: many retailers are not aware of their obligations. But only someone who acts with legal certainty is safe from unplanned costs and fines.
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Requirements in Germany: why the WEEE number is mandatory for manufacturers and retailers
According to the German Electrical and Electronic Equipment Act, all manufacturers of electrical and electronic equipment who wish to sell their products on the German market are obliged to register with stiftung elektro-altegeräte register (stiftung ear). This is to ensure that all distributors of electrical appliances fulfil their product responsibility and take back the waste electrical and electronic equipment they have put into circulation.
They are not entitled to market electrical appliances in Germany without prior registration with stiftung ear and a corresponding WEEE number. Consequently, a WEEE number is mandatory for every manufacturer in accordance with section 3 (1) of the German Electrical and Electronic Equipment Act.
Only those who have a subsidiary in Germany can register with stiftung ear and thus receive a WEEE number. Those who operate from abroad can, however, appoint a WEEE authorised representative in Germany, who will take care of the registration as a representative.
Who is considered a manufacturer under the German Electrical and Electronic Equipment Act?
WEEE Recycling and sustainability Directive
According to section 3 (1) of the German Electrical and Electronic Equipment Act, a manufacturer is any natural or legal person who sells electrical or electronic equipment under its own name or brand in Germany. In addition, a (quasi-)manufacturer is considered to be a person who offers electrical or electronic equipment for the first time in Germany (e.g. importers) or sells it directly to end users in Germany with the help of distance communication technology and is based in another EU member state or in a third country (e.g. online shops).
A manufacturer according to the German Electrical and Electronic Equipment Act is therefore any natural or legal person in Germany who …
- Manufactures and offers electrical or electronic equipment under its own name.
- Has electrical or electronic equipment manufactured (e.g. by OEMs) and offers it under its own name.
- Offers electrical or electronic equipment from other manufacturers under its own name.
- Offers electrical or electronic equipment from abroad in Germany for the first time (importer).
Attention: In addition, any distributor who, intentionally or negligently, offers new electrical or electronic equipment for sale from manufacturers, or their authorised representatives, who are not or not properly registered will also be regarded as a manufacturer.
Why do manufacturers have to state the WEEE number?
If a manufacturer is registering with stiftung ear for the first time, he will then be given a WEEE registration number, provided that the registration was successful. This is a kind of user or customer number that can also be used for future product registrations. The number is comprised of:
- A country code (e.g. DE for Germany)
- A sequence of 8 digits
According to section 6 (9) of the German Electrical and Electronic Equipment Act, manufacturers must state the respective WEEE number on invoices and during product sales from now on.
Search for a WEEE number: in the stiftung ear database
As stiftung ear is the official directory of all registered electrical manufacturers (or their authorised representatives) in Germany, all manufacturers can be viewed online in the database. For example, you can search using the manufacturer’s name or its WEEE number. This makes it easier to check whether the WEEE Directive is actually being implemented at a national level. Even though the WEEE number usually always remains the same, each equipment type or each new brand of a manufacturer must be registered separately with stiftung ear. In the event of doubt, it is also possible to revoke a registration that has already been granted.
Requirements within the EU: a separate WEEE registration number for each country
While the WEEE Directive is implemented in Germany by the German Electrical and Electronic Equipment Act (ElektroG), other national laws apply in other EU countries. Although these are also based on the WEEE Directive, there is no central registration authority in the EU. Consequently, there are also no uniform WEEE numbers. Manufacturers must therefore fulfil their WEEE number obligation individually in each country and register separately with the competent registration authorities.
Despite the uniform directive, the registration, categorisation and take-back of electrical and electronic equipment in other European countries are still handled very differently. For example, additional or different product/sub-categories apply in some countries compared to Germany – despite the changeover to open scope in 2018. Manufacturers and retailers should therefore consider working with a partner to ensure Europe-wide/worldwide WEEE compliance.
Which products have to be registered?
When it comes to registering electrical equipment under the WEEE Directive, it does not matter whether the equipment is B2B (commercially used) or B2C (privately used), although much stricter requirements apply to B2C equipment: For example, manufacturers who sell their products directly to end consumers are obliged to provide insolvency-proof guarantees.
WEEE registration number: how registration works
In any case, take care of registering your equipment and applying for the WEEE registration number at an early stage. After all, you can only put equipment on the market if the result of your WEEE registration with stiftung ear is positive. The registration process usually takes place in several steps:
- Creating a user account on the stiftung ear online portal (entering company data and contact persons)
- Inputting of specific registration data (brand, type of equipment, structural/technical properties)
- Warranty information for the equipment
- Uploading of relevant documents (e.g. pictures and brochures)
- You will receive information about the outcome of the proceedings after around 8-10 weeks.
If you are not 100% sure whether equipment offered by you is subject to compulsory registration according to ElektroG, you can submit a ‘Feststellungsantrag’ (request for declaration) to stiftung ear in advance. In addition to an existing user account and a detailed product description, this also requires a brief justification of your doubts. You will then receive a binding confirmation as to whether or not you have to register the equipment.
Deutsche Recycling is your professional and reliable partner throughout the entire registration process to ensure that the WEEE registration for your electrical/electronic equipment runs smoothly and that you can start selling your products as soon as possible. Find out more now!
WEEE registration number: What are the costs for manufacturers?
The registration process involves costs for every manufacturer, brand, and type of device. Additional fees may include:
- Costs for providing proof of insolvency-proof guarantees for B2C products
- Costs for verifying plausibility
- Costs for any changes to registration data
- Costs in the event that an application cannot be submitted through the electronic online portal
- Costs for appointing an authorized representative
The question of how high the expenses for the entire registration process are in individual cases cannot therefore be answered in general terms, but depends on the respective manufacturer and the individual situation.
We will be happy to advise you. Contact us quickly and easily.
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WEEE National (GER-GER)
Are you a manufacturer or distributor of electrical appliances within Germany?This means you are subject to the German Electrical and Electronic Equipment Act (ElektroGesetz). In Germany the WEEE directive is enforced by the authority of stiftung ear.
WEEE International (INT-GER)
If you are a supplier or manufacturer from abroad and want to sell your products on the German market, you are also subject to the German ElektroG. In Germany the WEEE directive is enforced by the authority of stiftung ear.
WEEE International (INT-INT)
Are you a manufacturer or distributor of electrical devices supplying your products on different international markets? In this case you are subject to the international WEEE directive, which, depending on the specific country, has been implemented by different national laws and regulations.