Companies without a physical presence in Germany are legally required to appoint an authorized representative to comply with the Electrical and Electronic Equipment Act (ElektroG). This requirement has been in place for over 10 years and is strictly enforced by the national registration authority, Stiftung EAR. As of July 1, 2023, major online marketplaces are obligated to verify your compliance, making this an urgent priority. Furthermore, a similar mandate for batteries under the Battery Act (BattG) will become effective on August 18, 2025, requiring immediate preparation. Ignoring this obligation means you cannot legally sell your products in Germany. You must take action now to comply with these EU directives. For companies that have not yet acted, the fastest way to secure compliance is to consult with an EPR expert. This legal framework makes it clear that appointing a representative is a foundational step for market entry.

An authorized representative is more than an administrator; they are your legal proxy for all EPR matters in Germany. Their appointment must be documented in a written contract in the German language for a minimum of three months to be valid. This entity takes on full responsibility for fulfilling your producer obligations, a critical function for any foreign seller. Their duties are extensive and legally binding. Here are the core responsibilities they manage:

• Registering your company and products with the correct authorities, such as Stiftung EAR for electronics and batteries.
• Submitting regular reports on the volume of products and packaging you place on the German market, often measured in kilograms.
• Ensuring your participation in a certified take-back and recycling scheme for all relevant product categories.
• Acting as the official point of contact for all German environmental agencies, handling inquiries and legal notices.
• Managing financial guarantees required for B2C electronics to cover future recycling costs, with some guarantees exceeding €1,000.
• Keeping your registrations current and compliant with any of the 15+ amendments to environmental laws in the last decade.

Understanding these duties helps clarify why choosing a competent partner is essential for anyone looking to appoint a WEEE and battery representative.

The need to appoint an authorized representative for the German market applies to any producer without a legal branch in Germany. The term ‘producer’ is defined broadly and includes more than just manufacturers. You are considered a producer if your business performs any of the following actions for the first time on the German market. For instance, if you sell more than 100 units annually via distance selling, you fall under these rules. Even a single product sold directly to a German end-user triggers these obligations. You must appoint a representative if you:

1. Manufacture goods under your own brand and sell them directly to German customers.
2. Sell products from other manufacturers under your own brand name in Germany.
3. Import goods from outside Germany to offer them for the first time on the German market.
4. Operate as an online retailer shipping products cross-border directly to private or business end-users in Germany.

These rules ensure that every company profiting from the German market contributes to its environmental programs, a key part of your WEEE obligations for distance sellers.

Failing to comply with German EPR laws is a significant financial and operational risk. The authorities can impose fines of up to €100,000 for violations of the ElektroG, such as incorrect registration. For packaging law violations, penalties can reach as high as €200,000. Beyond fines, the most immediate threat is a complete sales ban, which online marketplaces are now required to enforce for non-compliant sellers. Since July 2023, thousands of non-compliant listings have already been deactivated by platforms. The consequences are severe and designed to ensure 100% participation. These risks underscore the need to fulfill producer responsibility without delay. Proactive compliance is the only way to avoid these damaging outcomes.

To appoint an authorized representative for the German market, you must follow a clear, legally defined process. This ensures your chosen partner is officially recognized by German authorities like Stiftung EAR. The entire process can be completed in as little as 2-4 weeks with the right partner. Here is the streamlined, 4-step approach:

1. Select a Qualified Partner: Choose a reliable service provider with a physical branch in Germany and proven experience in EPR compliance.
2. Sign a Formal Mandate: Execute a written agreement in German that officially appoints the representative and details their responsibilities. This contract must be for a minimum of three months.
3. Provide Necessary Documentation: Supply your representative with company details, product specifications, and brand information required for registration.
4. Confirm Registration: Your representative will complete the registration with the relevant German authorities. Once confirmed, you will receive your WEEE or BattG registration number, securing your legal right to sell.

This structured process is the first step to managing your German EPR obligations effectively.

Selecting the right authorized representative is a strategic decision that impacts your business for years. A dependable partner does more than file paperwork; they provide security and simplify complex legal demands. Deutsche Recycling offers a full-service solution, managing all your obligations under the ElektroG, VerpackG, and BattG. With over 10 years of experience, we ensure 100% legal conformity, allowing you to focus on your core business. A full-service provider eliminates the need to coordinate with multiple agencies and systems. Don’t wait for a legal warning or a sales stop. Contact Deutsche Recycling now to ensure your business complies with all regulations quickly and efficiently. Our experts are ready to provide an individual consultation to secure your access to the German market. This proactive approach is central to a complete guide to German EPR laws.