Germany’s Electrical and Electronic Equipment Act (ElektroG) directly translates the EU’s WEEE Directive into national law. It requires any company placing electronic products on the German market to handle their end-of-life recycling. For companies without a legal establishment in Germany, §8 of the ElektroG makes it mandatory to appoint a WEEE authorized representative. This rule has been strictly enforced since 2012, affecting thousands of international online sellers and distributors. Ignoring this legal duty is not an option and leads to immediate consequences. You must appoint a representative to legally operate. This legal framework ensures that everyone of the millions of tons of e-waste is managed responsibly.

Your WEEE authorized representative acts as your legal proxy in Germany for all EPR-related matters. Their first task is managing your registration with the Stiftung EAR, the national register, to obtain your unique WEEE-Reg.-Nr. DE. This number must be displayed on invoices and online marketplaces, proving your compliance to the authorities and your 250+ B2B partners. The representative also handles all mandatory reporting of sales volumes, which can be monthly for B2C products. They also provide the required insolvency-proof guarantee, ensuring funds are available for future recycling costs, a process that can take over 4 weeks.

Key duties include:

• Acting as the official contact for all German environmental authorities.
• Completing the initial registration for all your brands and product types with Stiftung EAR.
• Submitting monthly and annual reports on the volume of equipment placed on the market.
• Providing and maintaining an insolvency-proof financial guarantee for B2C products.
• Coordinating the take-back and recycling logistics for your products.
• Ensuring all your product labeling meets the specific requirements of the ElektroG.

These tasks transfer the administrative burden from you to a dedicated local expert, as detailed in our German EPR consulting services.

The German Federal Environment Agency (UBA) actively enforces the ElektroG, and penalties for non-compliance are severe. Selling electronic equipment without a valid WEEE registration can trigger fines of up to €100,000 per violation. This isn’t a one-time risk; each product sold without registration can be considered a separate violation. Beyond fines, authorities can issue a complete sales ban, effectively stopping your German operations overnight. Many companies underestimate that competitors can also report non-compliant businesses, leading to investigations. The public register at Stiftung EAR makes it easy for anyone to check a company’s compliance status in under 5 minutes. You must register with Stiftung EAR to mitigate these financial and operational risks.

Appointing a WEEE authorized representative is a formal process with clear legal steps. Taking prompt action ensures you can obtain your WEEE number in as little as 3 to 4 weeks if all documentation is correct. Delays in this process directly translate to lost sales.

Follow these four essential steps:

1. Select a Qualified Representative: Choose a reliable partner based in Germany, like Deutsche Recycling, who can manage all legal duties.
2. Sign a Formal Mandate: The appointment must be made in writing, in German, and for a minimum duration of three months.
3. Confirmation by Stiftung EAR: Your chosen representative uses the signed mandate to get confirmed by Stiftung EAR through their online portal.
4. Registration and WEEE Number Issuance: Once confirmed, the representative completes the product registration, and you are issued a WEEE number, allowing you to legally sell.

This structured approach is critical to get your WEEE registration number without unnecessary delays.

Securing a WEEE number is just the first step; ongoing compliance requires continuous management. The regulations under the ElektroG are updated periodically, with ElektroG3 in 2022 introducing new obligations for B2B manufacturers. A dependable partner does more than just register your company. They provide a comprehensive service that adapts to these changes, protecting you from future risks. A full-service provider manages reporting deadlines for over 12 reports annually, preventing penalties from missed filings. This includes handling all communication with authorities and managing the complex logistics of product take-back and recycling. This integrated approach allows you to focus on your core business with the certainty that your environmental obligations are 100% met. To understand your full range of duties, see our guide on your obligations under the ElektroG.

The requirements of the ElektroG are active and enforced today. Every day you operate without a WEEE authorized representative is a day you are exposed to significant legal and financial risk. The time to act is now. Waiting for a warning from the authorities means you have already been discovered, and penalties are imminent. By partnering with an expert, you can achieve compliance in just a few weeks and secure your business in one of Europe’s largest markets. Deutsche Recycling provides a direct path to full compliance. Our team of experts handles every step, from appointing a representative to managing your ongoing duties. Contact us today for an individual consultation to secure your WEEE registration and protect your German market access. This is a critical step for all distance sellers to Germany.