The German Electrical and Electronic Equipment Act (ElektroG) translates the EU WEEE Directive (2012/19/EU) into national law . It mandates that any company first placing electronic goods on the German market is responsible for their eventual disposal. This principle of Extended Producer Responsibility (EPR) applies to manufacturers, importers, and online retailers selling cross-border into Germany . Since January 1, 2022, the updated ElektroG3 has tightened these rules, expanding obligations for many businesses . You must take immediate action to comply with these regulations. For expert guidance on your specific obligations, understand your obligations under the ElektroG today. These legal duties are not optional and form the basis of your market access.

Before selling a single item, you must register with the national register for waste electric equipment, stiftung ear . This registration provides you with a unique WEEE-Reg.-Nr., which must be displayed on invoices and sales platforms . As of July 1, 2023, major online marketplaces like Amazon are legally required to verify this number and will delist any non-compliant products . Failing to register before market entry can trigger fines of up to €100,000. The registration process requires detailed information about your brand and equipment types. This is the first critical step for legal market participation.

Here are the essential registration steps:

• Appoint a German-based authorized representative if your company has no physical presence in Germany .
• Provide detailed information for every brand and type of equipment you plan to sell .
• For B2C products, you must furnish an annual, insolvency-proof financial guarantee to cover future recycling costs .
• Submit your application to stiftung ear to receive your WEEE registration number.

Navigating this process is complex; let us help you register for WEEE in Germany to avoid costly errors. This registration is the foundation of your compliance strategy.

For companies without a legal entity in Germany, appointing an authorized representative is not optional—it is a mandatory requirement under ElektroG . This representative assumes all legal duties and responsibilities on your behalf, from registration to reporting. They act as the official point of contact for German authorities, managing all administrative tasks. More than 100 companies have relied on such representatives to ensure seamless compliance. Without a representative, you cannot legally register or sell in Germany. This requirement ensures foreign sellers are held to the same standards as domestic ones. It is vital to find a WEEE authorized representative to handle these critical functions.

Compliance extends to the physical product and its end-of-life handling. Every electronic device must be labeled with the crossed-out wheeled bin symbol, indicating it cannot be disposed of in household waste . Additionally, clear manufacturer identification must be present so the product can be traced back to you . Retailers, including online sellers with over 400 m² of storage and shipping area, must also provide a 1:1 take-back option for old devices when a customer buys a new, similar one . Failure to offer these take-back options can result in significant penalties. These measures ensure consumers can easily participate in the recycling process. This system is a core component of Germany’s strategy to increase its collection rate of e-waste.

If your electronic products contain batteries, you have a second set of compliance duties under Germany’s Battery Act (BattG) . Similar to ElektroG, you must register with stiftung ear for batteries before placing them on the market. This registration provides a separate Batt-Reg.-Nr. DE . Since January 1, 2021, this registration has been mandatory for all battery producers . The law requires you to join an approved take-back system to manage battery recycling. Many businesses overlook that even products with built-in batteries require this dual registration. You must license batteries for your products to avoid violations. This ensures that the hazardous materials within batteries are handled safely.

The consequences of non-compliance are severe and designed to enforce participation. The German Federal Environment Agency (UBA) can issue fines up to €100,000 for each administrative offense, such as selling without registration . Beyond fines, authorities can issue a complete prohibition of sale, effectively halting your business in Germany . Competitors can also file legal complaints, leading to costly court proceedings. Since 2023, online marketplaces are now obligated to delist sellers who cannot prove their EPR compliance, making enforcement immediate and unavoidable . The financial and reputational risks are simply too high to ignore. Now is the time to act.

The regulatory landscape for German market access for electronic goods is complex and unforgiving. The requirements of the ElektroG, from registration and labeling to take-back systems, demand immediate and thorough action. Waiting is no longer an option, as automated checks by online platforms and active enforcement by authorities create significant business risks. Ensuring 100% legal conformity is not just about avoiding fines—it is about securing your continued access to over 83 million consumers. If you have not yet addressed your EPR obligations, your business is already at risk. Contact Deutsche Recycling today for a consultation and let our experts manage your compliance swiftly and professionally. We ensure you meet every requirement, so you can focus on your core business.