Since Brexit, UK companies are no longer EU-internal suppliers but are treated as ‘producers’ or ‘first distributors’ when selling to Germany. This shift places direct legal responsibility on your company for the entire lifecycle of your products and packaging. Over 15,000 UK businesses export goods to Germany, and each one must comply.

Three primary laws form the core of Germany’s EPR framework: the Packaging Act (VerpackG), the Electrical and Electronic Equipment Act (ElektroG), and the Battery Act (BattG). Compliance is not optional and is required from the very first item you sell. There are no minimum sales thresholds for most obligations.

Ignoring these duties exposes your business to significant financial and operational risks. You must take action now to ensure your access to the German market, which represents over 6% of all UK exports, remains secure. Understanding these regulations is the first step toward safeguarding your business. For a complete overview, you can get a guide to German EPR laws.

These regulations require immediate registration and reporting, creating a new set of administrative tasks for your UK-based team.

The German Packaging Act (VerpackG) affects every company placing packaging on the German market, including all shipping and product packaging. Compliance involves a mandatory two-step process that must be completed before your goods are sold. First, you must register with the Central Agency Packaging Register (ZSVR) in the public LUCID database.

Second, you must license your packaging volumes with a state-approved dual system, which finances the nationwide collection and recycling of your materials. Failing to participate in a dual system can result in fines of up to €200,000 per violation. There is no de minimis limit; the law applies from the first box or mailer bag you ship.

To ensure you meet all requirements, follow these steps:

• Register your company and brand names in the LUCID portal.
• Calculate your annual packaging volumes for paper, plastic, glass, and other materials.
• Sign a contract with a certified dual system to license these volumes.
• Enter your dual system participation and report your volumes in LUCID.

These steps are critical for legal market entry. You can learn how to comply with the German Packaging Act and avoid distribution bans.

With these packaging rules mastered, you must next consider any electronic products you sell.

If your UK company sells electrical or electronic equipment (EEE) to Germany, you fall under the Electrical and Electronic Equipment Act (ElektroG), Germany’s implementation of the WEEE Directive. This law mandates that producers are responsible for financing the collection and recycling of their products. A critical requirement for any producer without a physical branch in Germany is the appointment of an authorized representative.

This authorized representative acts as your legal contact in Germany, handling all obligations on your behalf. Without a registered authorized representative, you are legally barred from selling EEE in Germany. The representative registers your company and products with the national register, Stiftung Elektro-Altgeräte Register (stiftung ear).

Your WEEE number, issued upon successful registration, must be displayed on invoices and online listings. Marketplaces like Amazon and eBay are now legally required to verify this number and will delist non-compliant products, blocking sales from over 50 million potential customers in Germany. Fines for non-compliance with ElektroG can reach €100,000. To understand your specific duties, review the WEEE obligations for distance sellers.

If your electronic products also contain batteries, another layer of regulation applies.

The German Battery Act (BattG) applies to all types of batteries and accumulators, including those integrated into vehicles or electronic devices. As a UK-based exporter, you are considered the ‘producer’ and must ensure compliance before your products enter the German market. This includes registering with the same authority as for EEE, the stiftung ear.

Producers are obligated to join a government-approved take-back scheme to manage the collection and recycling of spent batteries. There are currently 5 approved producer take-back systems for portable batteries in Germany. All batteries must also be correctly labelled with the crossed-out wheeled bin symbol to inform consumers about proper disposal.

The key obligations for UK companies under the BattG are:

1. Register as a producer with stiftung ear before placing any batteries on the market.
2. Join an approved battery take-back system to fulfill collection and recycling duties.
3. Ensure all batteries and product packaging are correctly labelled.
4. Submit regular reports on the volume of batteries placed on the market.

Non-compliance can lead to fines and sales prohibitions, disrupting your supply chain. To simplify these duties, you can manage your German EPR obligations through a single service provider.

A key element for compliance, particularly for ElektroG, is appointing a local representative.

For UK companies without a legal entity in Germany, appointing an Authorized Representative (AR) is a mandatory step for ElektroG compliance and an option for VerpackG. The AR must be a natural or legal person based in Germany and serves as your official point of contact for the authorities, such as stiftung ear.

The appointment must be made via a written contract in German and officially recorded in the respective portals. This representative takes on your legal obligations, from initial registration to ongoing reporting. Attempting to sell EEE without a confirmed AR is a direct violation of the law and will result in a sales ban.

Your AR is responsible for fulfilling all producer obligations, including registering your brands and equipment types and submitting annual volume reports. Choosing an experienced and reliable AR is critical for your business success in Germany, as they ensure all deadlines and requirements are met correctly. This step is foundational to your market presence. You must appoint an authorized representative to proceed legally.

Understanding this role is vital to appreciating the serious consequences of non-compliance.

The financial and operational penalties for ignoring German EPR laws are severe. Authorities can impose fines of up to €200,000 for failing to license your packaging with a dual system under VerpackG. Simple registration errors under the same act can cost you up to €100,000.

For violations of the ElektroG, such as failing to register with stiftung ear or appoint an authorized representative, fines can reach €100,000. Beyond the financial penalties, authorities can issue a complete distribution ban, effectively halting all your sales in Germany. Online marketplaces are now legally obligated to delist non-compliant sellers, meaning your products can disappear from their platforms overnight.

These risks are not abstract threats; they are actively enforced. You must act now to avoid business disruption. The only way to operate safely is to ensure you meet all legal requirements for shipping to Germany.

To prevent these outcomes, a clear and immediate action plan is necessary.

Navigating German EPR compliance from the UK requires a structured approach. Taking proactive steps today protects your business from fines and ensures uninterrupted access to one of Europe’s largest markets. Overlooking even one requirement can halt your operations.

Here is your essential action plan:

• 1. Product & Packaging Audit: Identify every product you sell to Germany that falls under VerpackG, ElektroG, or BattG.
• 2. Appoint Representatives: If you sell EEE, immediately contract a certified Authorized Representative based in Germany.
• 3. Register with Authorities: Complete your registration in the LUCID packaging register and with stiftung ear for electronics and batteries.
• 4. License Your Volumes: Contract with a dual system for your packaging and a take-back scheme for batteries.
• 5. Report and Maintain: Establish a process for accurate, ongoing reporting of your sales volumes to all required portals.

These complex, multi-step processes demand expertise and time that many companies cannot spare. The fastest and most reliable way to achieve 100% compliance is to partner with a specialist. Contact Deutsche Recycling now for an individual consultation and let our experts handle every aspect of your German EPR obligations, so you can focus on your core business. Explore our cross-border EPR solutions to get started.