The window for voluntary compliance with EU environmental directives has closed. Since 2022, German law requires all producers to register before placing a single item on the market. Failure to comply can trigger immediate penalties, including fines that can reach €200,000 for certain violations. Online marketplaces like Amazon and eBay are now legally obligated to verify your EPR registration numbers. Without valid proof of compliance, they will suspend your accounts, effectively halting 100% of your sales. This is not a future problem; it is an immediate business risk. Every day you delay action increases your legal and financial exposure. If you have not yet addressed your obligations, you must get help with German compliance to protect your market access. These regulations form the foundation of your legal ability to operate in Germany.

Three primary laws govern Extended Producer Responsibility in Germany, affecting nearly every physical product sold. The Verpackungsgesetz (VerpackG) applies to all packaging, including product, shipping, and service packaging, with no minimum volume threshold. The Elektro- und Elektronikgerätegesetz (ElektroG) covers electrical and electronic equipment (WEEE), while the Batteriegesetz (BattG) regulates all types of batteries, even those integrated into other products. Any business acting as the initial distributor of these goods is considered a ‘producer’ and is liable. This includes German manufacturers, foreign importers, and cross-border online retailers shipping directly to consumers. Understanding which laws apply to your specific product portfolio is the first step toward achieving the necessary licensing. This legal framework requires a structured approach to market entry.

To legally sell in Germany, you must complete several mandatory steps before your products enter the market. These actions ensure you can fulfill producer responsibility correctly.

1. Appoint an Authorized Representative: If your company is not based in Germany, you must legally appoint a German-based authorized representative to manage your EPR duties for electronics and batteries.
2. Register with National Authorities: You must register each product category with the correct agency. This means registering with the ‘Zentrale Stelle Verpackungsregister’ (ZSVR) via the LUCID portal for packaging and with ‘stiftung ear’ for electrical equipment and batteries.
3. Contract with a Producer Responsibility Organization (PRO): For packaging, you must sign a contract with a dual system (PRO) to handle the collection and recycling of your materials.
4. Declare Volumes and Pay Fees: You are required to submit regular, accurate reports on the volume and type of products you place on the market and pay the corresponding eco-fees to your PRO.

Completing these steps provides you with the EPR registration numbers required by law and by marketplaces. With these fundamentals in place, you can address the specifics of packaging compliance.

The German Packaging Act (VerpackG) affects every company placing goods on the German market, starting from the very first item shipped. This law covers all packaging components, including primary product packaging, secondary shipping boxes, and filling materials. To comply, you must complete a two-part process. First, register your company details in the LUCID packaging register, a public database that ensures transparency. Second, you must license your packaging volumes with a dual system provider, which costs vary based on material type and weight. Many businesses incorrectly assume this only applies to large volumes, but there is no minimum threshold. Proper packaging licensing is a critical component of your overall compliance strategy. You can streamline your packaging licensing with expert guidance. Once packaging is handled, you must turn your attention to electronic goods.

Placing electronics or batteries on the German market involves more complex obligations under the ElektroG and BattG. Beyond registration with stiftung ear, producers must provide an insolvency-proof guarantee to cover potential future disposal costs. Furthermore, specific labeling, such as the crossed-out wheeled bin symbol, is mandatory on all electronics and batteries to inform consumers about proper disposal. Producers of electronics must also offer a take-back service for used products. A key requirement for non-German companies is the mandatory appointment of an authorized representative located in Germany. This representative assumes legal responsibility for all your ElektroG and BattG obligations. You must appoint an authorized representative to even begin the registration process. This step is non-negotiable for foreign sellers.

Managing these complex, multi-layered requirements internally consumes significant resources and carries a high risk of error. A single missed deadline or incorrect volume declaration can lead to severe consequences. Partnering with a specialist like Deutsche Recycling removes this burden and provides guaranteed legal security.

• Full-Service Management: We handle all registrations, reporting, and communication with German authorities on your behalf.
• Authorized Representation: We can act as your legally required authorized representative for WEEE and batteries.
• Cost-Efficiency: Our experts ensure your declarations are accurate, preventing overpayments and saving you money.
• Business Continuity: We provide the necessary EPR numbers to keep your marketplace accounts active and your supply chain moving.

By entrusting your compliance to us, you can focus entirely on your core business operations. Take the final step toward securing your place in the German market.

The regulations are in full effect, and enforcement is strict. You can no longer afford to postpone action. Every product you ship without the proper licenses is a direct violation of German law. The path to compliance requires immediate and decisive steps. To avoid sales interruptions and financial penalties, you must ensure you have met all requirements under the VerpackG, ElektroG, and BattG. The quickest and most reliable way to achieve this is to work with a seasoned expert. Contact Deutsche Recycling today for an individual consultation and ensure your operations are 100% compliant with all regulations. Let us help you get your products licensed for the German market without delay.