The window for voluntary compliance with German EPR laws has closed. Enforcement is active, with fines for non-compliance reaching up to €200,000 per violation. More critically, online marketplaces are now legally required to verify your EPR registration numbers, leading to account suspensions for non-compliant sellers since July 2022 for packaging and January 2023 for electronics. Every day of delay is a day your business is exposed to sales bans and significant financial loss. The time for deliberation is over; immediate action is required to protect your market access. If you have not yet started this process, you must contact an expert partner like Deutsche Recycling to expedite your registration. Understanding your obligations is the first step, and you can understand your obligations under the ElektroG to begin. This urgency is not just about avoiding penalties, but about maintaining your fundamental ability to operate in one of Europe’s largest markets.

Before tackling the specific categories, every company needs a core set of documents for any EPR registration in Germany. These details form the basis of your applications with the central authorities, whether it’s the ZSVR for packaging or Stiftung EAR for electronics and batteries. Accuracy here is critical, as discrepancies can cause delays of several weeks. You will need to prepare the following information:

• Company Name, Full Address, and Contact Details (Phone, Email)
• VAT Identification Number (Umsatzsteuer-Identifikationsnummer) or Taxpayer Reference Number
• National Identification Number (e.g., Commercial Register Number or Trade License Number)
• Name of a natural person authorized to represent the company (e.g., CEO or Managing Director)
• A comprehensive list of all brand names under which you market your products in Germany.

Having these 5 key pieces of information ready streamlines the entire process significantly. These documents are your entry ticket; without them, you cannot proceed to the next stage of specific registration. For a full overview, a complete guide to German EPR laws can provide additional context. With this foundational paperwork in hand, you can then address the unique requirements of each product stream.

To comply with the German Packaging Act (VerpackG), you must register in the LUCID portal, which is managed by the Central Agency Packaging Register (ZSVR). This registration is non-delegable and must be completed before your first sale. The LUCID registration number is your proof of compliance. Beyond the foundational documents, you must provide specific details about your packaging activities. You will need:

1. A signed contract with a dual system provider in Germany for the collection and recycling of your packaging.
2. Data on your packaging volumes for the calendar year, broken down by material type (e.g., paper, plastic, glass) in kilograms.
3. The name of your chosen dual system, which must be declared in the LUCID portal.

Failure to report volumes to both your dual system and LUCID is a common error leading to non-compliance. These steps are mandatory for every single company, as there is no de-minimis threshold for registration. To ensure you cover all bases, use a checklist for selling products legally. Once packaging is handled, you must turn your attention to electronic equipment if it’s part of your portfolio.

For electrical and electronic equipment (WEEE), registration is handled by Stiftung EAR (Elektro-Altgeräte Register). This process is notably complex and can take 8-10 weeks, so starting early is essential. Companies without a physical presence in Germany must appoint an authorized representative to manage their obligations. The key documents and information required are:

• Detailed product information, including the specific type of equipment (e.g., B2C, B2B) and brand name for each registration.
• For B2C products, proof of an insolvency-proof guarantee, which ensures recycling costs are covered even if your company fails.
• The name of your commissioned recycling system or take-back partner.
• Product photos and brochures may be required to support the classification of your devices.

Upon successful registration, you receive a WEEE-Reg.-Nr., which must be displayed on invoices and online listings. Many companies underestimate the need for an insolvency-proof guarantee, which is a frequent point of failure in the application. You can learn more about how to register for WEEE in Germany to avoid these pitfalls. The next step involves addressing any batteries sold with your products or as standalone items.

The Battery Act (BattG) also requires registration with Stiftung EAR, a change that took effect in January 2021. If you sell electronics with batteries, you need separate registrations for both WEEE and batteries. The required information is similar to WEEE but has its own nuances. You must provide:

1. The battery type you are placing on the market (e.g., portable, industrial, or automotive).
2. The brand name under which the batteries are sold.
3. For portable batteries, the name of the approved take-back system you have joined.
4. For automotive or industrial batteries, a declaration that you have established a compliant return facility for end-users.

A common mistake is assuming WEEE registration automatically covers the batteries inside the devices; it does not. After successful registration, you will receive a Batt-Reg.-Nr. as your proof of compliance. Given the complexity, it is vital to avoid common errors in registration. With all documents gathered, the path to full compliance becomes clear.

Gathering these documents is only the first step in a complex, ongoing process. Each registration requires careful submission, and ongoing reporting obligations demand constant attention. A single mistake can jeopardize your ability to sell in Germany. This is why hundreds of companies trust Deutsche Recycling to manage their entire EPR compliance portfolio. We handle the document preparation, submission to authorities like Stiftung EAR, and all necessary communication, guaranteeing 100% legal conformity. Instead of navigating the complexities of the Stiftung EAR registration yourself, let our experts take over. We ensure every detail is correct, from the initial application to your final EPR number. Don’t risk your business on administrative hurdles. Contact Deutsche Recycling today for a consultation and ensure your EPR registration is handled quickly and professionally.