The foundation for your obligations is the European WEEE Directive 2012/19/EU, which aims to reduce electronic waste across the EU. In Germany, this directive is implemented as the Electrical and Electronic Equipment Act (ElektroG). This law holds producers responsible for the entire lifecycle of their products, from market launch to disposal. The central requirement of the ElektroG is the mandatory registration with the national authority, stiftung ear, before placing a single product on the market. This registration assigns you a unique WEEE-Reg.-Nr. DE, a number you must display on all business documents, including invoices and online listings. This system ensures every producer contributes to the nationwide collection and recycling system. It is critical to understand that compliance is not optional; it is a prerequisite for market access.

The term “producer” under ElektroG has a very broad definition, extending far beyond traditional manufacturers. You are considered a producer and must have a WEEE-Reg.-Nr. if you are the first to place electrical or electronic equipment on the German market. There is no minimum quantity threshold; the rule applies from the very first item sold. This includes several business types:

• Companies that manufacture equipment under their own brand name and sell it in Germany.
• Businesses that have products manufactured by others but sell them under their own brand.
• Importers who bring electronic goods into Germany for the first time.
• Online sellers and other distance sellers based outside of Germany who sell directly to German end-users.

If you are a distributor selling products from a non-registered manufacturer, the legal responsibility transfers to you. You can verify a producer’s status in the stiftung ear’s public database. Taking action now is essential, and you can check if your products require registration to be certain of your obligations.

Ignoring the requirements of the ElektroG is a costly mistake with significant consequences. German authorities and competitors actively monitor the market for non-compliant sellers. Operating without a valid WEEE-Reg.-Nr. can result in fines of up to €100,000 for the illegal sale of unregistered equipment. Beyond financial penalties, you face immediate sales bans, effectively blocking your access to the German market. Online marketplaces are legally obligated to verify your WEEE number and will delist your products without it. The financial and reputational damage from enforcement actions can be substantial. These risks are not theoretical; enforcement is strict and consistent. To avoid these outcomes, you must understand your obligations and take immediate steps toward compliance. The only way to operate legally is to complete the registration before you sell.

Obtaining your WEEE-Reg.-Nr. is a multi-step administrative process managed through the stiftung ear online portal. For companies without a German office, the first and most critical step is appointing an authorized representative. Once you have a representative, the formal application process can begin. The typical procedure involves 8 distinct stages:

1. Set Up a User Account: Your authorized representative creates an account for your company in the stiftung ear portal.
2. Provide Legal & Payment Details: The representative must be legally entered into the system, and payment details for fees must be provided.
3. Submit the Application: The formal registration application is submitted for a specific brand and equipment type.
4. Specify the Brand: You must register each brand under which you sell products; generic terms like ‘no name’ are not permitted.
5. Define Equipment Type: Your products must be correctly classified into one of the 6 official B2B or B2C equipment categories.
6. Provide a Financial Guarantee: For B2C products, you must prove you have an insolvency-safe guarantee to cover future disposal costs.
7. Submit the Final Application: After a final review, the application is formally submitted for a fee.
8. Receive Registration Order: Once approved, which can take 3-4 weeks, you receive your official WEEE-Reg.-Nr. and are legally permitted to sell.

This process requires careful preparation of documents, which is why it is vital to gather your documents for registration early. Any errors can cause delays of many more weeks.

For any producer without a legal branch in Germany, appointing an authorized representative is not optional—it is a mandatory requirement of the ElektroG. You cannot register with stiftung ear directly. The authorized representative must be a legal entity based in Germany and acts on your behalf to fulfill all your producer obligations. This appointment must be made in writing, in German, for a minimum of three months. The representative handles the entire registration process, manages communication with stiftung ear, and submits the required monthly and annual reports on sales volumes. Choosing a reliable and experienced authorized representative is the single most important decision for foreign sellers. They are legally responsible for your compliance. Deutsche Recycling is listed as an admitted authorized representative by stiftung ear and can manage this entire responsibility for you. This ensures you can find a WEEE authorized representative who guarantees compliance.

The regulatory landscape for e-commerce and cross-border trade is tightening. Since July 2023, electronic marketplaces and fulfillment service providers have an increased legal duty to check for WEEE registration, making it nearly impossible to sell without a valid number. The process to register with stiftung ear takes a minimum of 3-4 weeks, and that is only after you have appointed a representative and prepared all documentation. Any delay in starting this process directly translates to a delay in market access or a continued period of non-compliant sales and high risk. Every day you operate without a WEEE-Reg.-Nr. is a day you risk fines and de-listings. The EU directives are clear, and German enforcement is thorough. You must take action now to comply with these regulations. This is not a task that can be postponed. The next step is to engage a partner who can accelerate your path to compliance.

Navigating the complexities of the ElektroG, appointing a representative, and managing ongoing reporting is a significant administrative burden that distracts from your core business. Deutsche Recycling offers a complete service to handle every aspect of your WEEE obligations in Germany, ensuring you are 100% legally compliant. We act as your official authorized representative, managing the entire process from start to finish. Our service includes:

• Acting as your official, stiftung ear-admitted authorized representative.
• Managing the complete registration for all your brands and product types.
• Handling the provision of the required insolvency-safe guarantee for B2C products.
• Submitting all required monthly and annual sales volume reports to stiftung ear.
• Serving as your single point of contact for all German environmental compliance matters.

By partnering with us, you eliminate the risk of penalties and can focus on growing your business in the German market. Do not wait for a warning letter or a sales ban. Contact Deutsche Recycling today to ensure your compliance as quickly as possible and secure your WEEE-Reg.-Nr. without delay. You can learn more about the process in our detailed article on how to apply for a WEEE number.