When selling electronics online to Germany, you are entering the EU single market, which is governed by a set of harmonized rules. The two most critical directives for electronics are the Waste Electrical and Electronic Equipment (WEEE) Directive 2012/19/EU and the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU. The WEEE Directive makes you, the seller, responsible for the entire lifecycle of your products, including their collection and recycling. This principle is called Extended Producer Responsibility (EPR) and applies to nearly all electronics, from toys to IT equipment.

The RoHS Directive complements this by restricting 10 specific hazardous substances, like lead and mercury, in the manufacturing process to protect human health. All products falling under these directives must also bear a CE mark, which declares conformity with all applicable EU health, safety, and environmental standards. Failure to comply with these foundational EU rules makes it impossible to legally enter the German market. These EU-level laws provide the framework, but their real-world application is defined by national legislation in each member state.

Germany implements the EU’s WEEE Directive through its national Electrical and Electronic Equipment Act (ElektroG). This law is the primary legal hurdle you must clear to get legal compliance for selling electronics online in Germany. The ElektroG mandates that any company first placing electronic products on the German market—including online sellers from abroad—is considered a ‘producer’. This status comes with significant obligations enforced by a central authority, the Stiftung Elektro-Altgeräte Register (EAR).

Before selling a single item, you must register with the Stiftung EAR to obtain a WEEE Registration Number (WEEE-Reg.-Nr.). This number must be displayed on invoices and provided to online marketplaces like Amazon, which are legally required to verify your compliance as of July 1, 2023. Without a valid WEEE number for each brand and equipment type you sell, your listings will be deactivated. Understanding these specific German requirements is the next critical step toward market entry.

Obtaining your WEEE number from Stiftung EAR is a multi-step administrative process that can take 8-10 weeks if all documents are correct. Any errors can cause significant delays and additional fees, blocking your sales. For companies without a physical presence in Germany, the law requires appointing a German-based Authorized Representative to handle these legal obligations on your behalf.

The registration process involves these key actions:

1. Create a User Account: Set up an account on the Stiftung EAR online portal, providing all company and contact details.
2. Appoint an Authorized Representative: A non-German seller must legally appoint a representative in Germany to manage compliance.
3. Provide Product Details: Submit specific data for each brand and type of equipment, including technical properties and images.
4. Secure a Guarantee: For B2C products, you must provide an insolvency-proof guarantee to cover future recycling costs.
5. Receive Your WEEE Number: Once approved, you will receive your WEEE-Reg.-Nr. DE, which unlocks your ability to sell.

Given the complexity, many businesses choose to streamline their WEEE registration with an expert partner. This ensures every step is completed correctly the first time, preventing costly delays and ensuring you can start selling as quickly as possible.

Registration is only the first part of your responsibility under the ElektroG. You are also legally required to finance and organize the take-back and recycling of your products once they reach the end of their life. Online retailers with over 400 m² of storage and shipping area must offer free 1:1 take-back when a customer buys a new, similar item. This means if you sell a new lamp, you must offer to take back the customer’s old one.

Your obligations for waste management include:

• Financing Collection: You must contribute financially to a national collection system for WEEE.
• Providing Take-Back Options: You must set up a legally compliant method for customers to return old devices.
• Consumer Information: Your website must clearly inform customers about their right to return old devices and the available options.
• Accurate Reporting: You are required to submit monthly and annual reports to Stiftung EAR detailing the volume of products you’ve placed on the market.

Many online sellers find managing a physical take-back system from abroad to be a major operational challenge. A full-service EPR partner can manage these complex logistical and reporting duties for you.

Compliance for electronics doesn’t stop with the device itself. Many products contain batteries, and all are shipped in packaging, each regulated by its own set of German laws. The German Battery Act (BattG) requires producers to register, label, and arrange for the collection of all types of batteries. Similarly, the German Packaging Act (VerpackG) mandates that anyone shipping packaged goods to German consumers must license their packaging with a dual system.

Non-compliance in these areas carries its own set of fines and can also lead to sales prohibitions. For example, under the new EU Batteries Regulation, products may require a CE mark specifically for the battery by August 2025. A comprehensive compliance strategy must account for all components of your product offering. This holistic approach is essential for long-term, risk-free operation in the German market, and a partner can help you license batteries and packaging efficiently.

Ignoring these regulations is not a viable business strategy. The German authorities, particularly the Federal Environment Agency (UBA), actively enforce the ElektroG and related laws. The financial consequences of non-compliance are severe and designed to be a strong deterrent. Fines for failing to register with Stiftung EAR before selling can reach up to €100,000 per violation.

Other potential penalties include:

• Sales Bans: Marketplaces are legally obligated to delist non-compliant products, immediately cutting off your revenue stream.
• Profit Skimming: Authorities can confiscate the profits earned from illegally sold products.
• Warnings and Legal Action: Competitors can issue costly legal warnings, leading to court proceedings.
• Reputational Damage: Being publicly cited for non-compliance can permanently damage your brand’s image with eco-conscious German consumers.

The risk of a €100,000 fine for a single administrative oversight should be a clear signal to every seller. The only way to eliminate this risk is to achieve full compliance before you make your first sale.

Navigating the web of EU directives and German laws is a significant administrative burden that distracts from your core business. The process is complex, time-consuming, and fraught with financial risk if handled incorrectly. This is why partnering with a specialist for international EPR compliance is the most effective solution for over 90% of online sellers.

A full-service provider like Deutsche Recycling handles every aspect of your legal obligations. This includes appointing an Authorized Representative, managing the entire Stiftung EAR registration, setting up a compliant take-back system, and handling all reporting. By entrusting your compliance to an expert, you gain 100% legal certainty and can focus entirely on growing your business. If you have not yet taken steps to comply with these EU directives, you must act now. Contact Deutsche Recycling today for a consultation to secure your compliance as quickly as possible.