The WEEE Directive classifies all Electrical and Electronic Equipment (EEE) into six distinct categories. This system has been mandatory since August 15, 2018, creating an ‘open scope’ that includes virtually any item with a plug, battery, or electrical field. You must determine where your products fit within these 6 groups to begin the compliance process. The German interpretation of the law, the ElektroG, even extends to passive equipment like cables and sockets as of May 1, 2019. Understanding these categories is the first step toward fulfilling your legal duties. You must understand your ElektroG obligations to proceed correctly. This classification dictates your specific registration and reporting requirements, so a precise assessment is essential. The next section provides a detailed breakdown to help you identify covered products.

To check if your products require WEEE registration, you must see if they fall into the defined equipment categories. Any device operating up to 1,000 volts AC or 1,500 volts DC is likely in scope. Here is a list of the 6 official WEEE categories:

• 1. Temperature exchange equipment: Includes refrigerators, air conditioners, and any device using fluids for cooling or heating.
• 2. Screens, monitors, and equipment with screens >100 cm²: This covers TVs, laptops, and tablets.
• 3. Lamps: All forms of fluorescent, LED, and high-intensity discharge lamps are included.
• 4. Large equipment: Any device with an external dimension over 50 cm, such as washing machines or large printers.
• 5. Small equipment: Any device with no external dimension over 50 cm, like vacuum cleaners, smoke detectors, or electronic toys.
• 6. Small IT and telecommunication equipment: Mobile phones, GPS devices, and routers with no external dimension over 50 cm fall here.

A surprising number of items, including musical greeting cards or trainers with lights, now require registration. A WEEE scope check is the only way to be certain. This broad scope means you are likely responsible for registration, which leads to the question of who is defined as a ‘producer’.

The term ‘producer’ under Germany’s ElektroG is much broader than just the original manufacturer. It includes any entity that first places EEE on the German market. This means you are considered a producer if you import products into Germany or sell them under your own brand name. The law is especially clear for cross-border e-commerce. If you are a distance seller shipping directly to German end-users, you are a producer and must comply. Foreign companies without a German office must appoint an Authorised Representative to handle these obligations. This representative manages all registration and reporting on your behalf. Many online sellers overlook this critical requirement. You must review your distance selling obligations immediately. Once you confirm your producer status, the next step is formal registration.

In Germany, all producers must register with the Stiftung Elektro-Altgeräte Register (EAR) before selling any EEE. This registration is not optional; it is a legal prerequisite for market access. The process requires submitting detailed information about your company, brands, and the specific types of equipment you sell. You will be issued a unique WEEE registration number (WEEE-Reg.-Nr.), which must be displayed on invoices and in online shop communications. The application process can take over 8 weeks, so delays can impact your sales launch. Here are the core registration requirements:

1. Appoint a German Authorised Representative (if you are based abroad).
2. Provide detailed descriptions and photos of your products.
3. Submit brand names under which you sell.
4. Provide an insolvency-proof guarantee for financing future waste collection and recycling (for B2C products).

Attempting to sell without a valid WEEE number is illegal. The process can be complex, which is why you should register with Stiftung EAR through an expert partner. Understanding the severe consequences of non-compliance underscores the urgency.

Ignoring WEEE registration is a costly mistake with consequences that extend beyond financial penalties. German authorities can issue fines of up to €100,000 for each violation, such as selling unregistered equipment. They can also legally demand you surrender any profits made from non-compliant sales. Beyond fines, you face immediate sales bans, and competitors can issue legal warnings (Abmahnungen) that lead to costly court proceedings. Since 2023, major online marketplaces like Amazon and eBay are legally required to verify your WEEE number and will block your listings without one. This means 100% of your sales can be halted instantly. To avoid this, you must get a WEEE registration number without delay. The only way to eliminate these risks is to take decisive action now.

The requirements of the WEEE Directive and Germany’s ElektroG are not suggestions; they are mandatory legal obligations. Every day you sell non-compliant products increases your risk of fines and sales prohibitions that could stop your business in its most important market. You must take action now to ensure you are operating legally within the EU. The registration process is detailed and requires specific documentation that can be challenging to navigate alone. Waiting for a warning from authorities is too late—the damage will already be done. Contact Deutsche Recycling today for an expert analysis of your obligations. We manage the entire registration process, from product classification to appointing an authorised representative, ensuring you achieve 100% compliance as quickly as possible. Don’t risk your business—request your individual compliance analysis now.