Germany’s approach to environmental protection holds producers accountable for waste, impacting any company selling goods to its 83 million consumers. Three primary laws form the basis of this Extended Producer Responsibility (EPR). The Packaging Act (VerpackG) affects virtually every seller, covering all packaging from the first gram. The Electrical and Electronic Equipment Act (ElektroG) targets WEEE, while the Battery Act (BattG) governs all battery types. Understanding these 3 regulations is the first step toward market access. You must understand your specific obligations under each law. These directives require immediate action to prevent your products from being blocked by marketplaces like Amazon as of January 2023.

The VerpackG requires a 2-step process: registration and licensing. First, you must register your company with the LUCID Packaging Register, managed by the ZSVR, before your first sale. This registration is free but mandatory for 100% of businesses. Second, you must license your annual packaging volumes with one of Germany’s 11 dual system operators. Fees are based on material type and weight, creating a financial incentive to reduce packaging. For example, 2022 recycling targets were set as high as 90% for materials like glass and ferrous metals. You must then report your licensed volumes and dual system partner back to the LUCID portal. This process ensures you fulfill your producer responsibility. Neglecting these steps can lead to fines of up to €200,000.

If you sell any product that requires an electric current, you fall under the ElektroG, Germany’s implementation of the WEEE Directive. This applies to devices with voltages up to 1,000V AC or 1,500V DC. Your primary obligation is to register as a producer with the Stiftung elektro-altgeräte register (EAR). Companies without a German legal entity must appoint an authorized representative. After registration, you receive a WEEE- Reg.-Nr., which marketplaces like eBay and Amazon require to keep your listings active. You must also guarantee the take-back and recycling of your products, often by commissioning a certified recycling system. These steps are critical to ensure WEEE compliance and avoid a sales ban.

The Battery Act (BattG) applies to all batteries, accumulators, and products containing them sold in Germany. As of January 2021, producers must register with the same authority as for WEEE, the Stiftung EAR. This replaced the previous, less formal notification to the Federal Environment Agency. The law mandates that producers join a take-back scheme to manage waste batteries, with 5 approved systems currently operating for portable batteries. The collection target for portable batteries was increased to 50%. Products must also be labeled with the crossed-out wheeled bin symbol. You must handle battery take-back correctly to maintain market access. Non-compliance is not an option and will be enforced.

German authorities and online marketplaces strictly enforce EPR laws. Failure to register in the LUCID portal can trigger fines of up to €100,000, while non-participation in a dual system can cost €200,000 per case. The ElektroG and BattG carry similar penalties, alongside an immediate distribution ban, meaning your products can no longer be sold. Since 2023, marketplaces like Amazon are legally required to verify your EPR registration numbers for packaging and WEEE, blocking non-compliant listings automatically. Competitors can also issue costly legal warnings for non-compliance. The only way to avoid these significant risks is through 100% compliance before you sell.

The requirements of the EU directives are already in full effect, and enforcement is stricter than ever. Waiting to act exposes your business to six-figure fines and a complete stop to your German sales. These complex regulations demand expert handling to ensure every detail is correct across all 3 laws. A single misstep in registration or reporting can render you non-compliant. The most secure and efficient way to meet your obligations is to partner with a specialist. Contact Deutsche Recycling immediately. Our experts will manage the entire process, guaranteeing you are 100% compliant to sell legally in Germany and focus on your core business.