Germany’s primary regulation for electronics is the Electrical and Electronic Equipment Act (ElektroG). This law translates the European WEEE Directive into national German law, affecting nearly every electronic device sold. It establishes Extended Producer Responsibility (EPR), making you liable for your product’s entire lifecycle. The law applies to both B2B and B2C equipment across 6 different categories. Ignoring these rules can result in fines of up to €100,000 per violation. Understanding this framework is the first step toward market access. You must also consider related laws like the Battery Act (BattG) and Packaging Act (VerpackG). These interconnected regulations create a complex compliance web that requires careful management.

These foundational laws dictate every subsequent action you must take before your first sale. The next critical step is official registration with the national authority.

Before selling a single item, you must register as a producer with the national register, stiftung ear. This registration is mandatory for all manufacturers, importers, and distributors placing electronics on the German market for the first time. The process involves submitting detailed company and product information to receive your unique WEEE registration number. This WEEE number must be displayed on all invoices and in business transactions. The application process can take more than 8 weeks, so early action is essential. Any delay in registration means a delay in your market entry. An incomplete application can add several more weeks to the timeline.

To register successfully, you must provide specific documentation:

• Company details and contact person information.
• The brand name under which you will sell the products.
• The specific type of equipment from the 6 official categories.
• For B2C products, an insolvency-proof guarantee is required annually.
• Details of your waste disposal contractor or take-back system.

For companies outside Germany, this process has an additional, non-negotiable requirement.

If your company does not have a physical branch in Germany, you are legally required to appoint an Authorized Representative. This representative must be a legal entity based in Germany and acts on your behalf to fulfill all your ElektroG obligations. They handle the entire stiftung ear registration process and assume legal responsibility for your compliance. The appointment must be made in writing, in German, and be valid for a minimum of three months. Without an Authorized Representative, foreign producers cannot legally register or sell electronics in Germany. This is a common point of failure for many international businesses entering the market for the first time. Your old registration and WEEE number will be canceled if you fail to appoint one.

Once your registration is complete and your representative is in place, your compliance duties shift to ongoing operational tasks.

Achieving your WEEE registration number is only the beginning of your responsibilities. Producers must adhere to several ongoing duties to maintain compliance. This includes submitting monthly reports on the volume of equipment placed on the market. You must also provide an annual report detailing the total tonnage of products sold and recycled. Failure to meet these reporting deadlines can lead to fines of €10,000.

Your key ongoing obligations include:

1. Monthly and Annual Reporting: Submit precise data on sales volumes to stiftung ear.
2. Insolvency-Proof Guarantee: Annually provide a financial guarantee to cover future disposal costs for B2C equipment.
3. Product Labeling: Mark all equipment with the crossed-out wheeled bin symbol and a producer identification mark.
4. Financing Recycling: Cover the costs for the collection, treatment, and environmentally sound disposal of your products.

Beyond the devices themselves, you must also account for the items that contain and power them.

Many electronic products contain batteries and are sold in packaging, triggering two additional sets of laws. The German Battery Act (BattG) and the Packaging Act (VerpackG) create separate EPR obligations. Under the BattG, producers must register with stiftung ear and ensure the take-back and recycling of all battery types. From August 18, 2025, foreign producers of batteries will also need a German Authorized Representative. Similarly, the VerpackG requires you to license your packaging with a dual system and register in the LUCID register. Marketplaces like eBay and Amazon are now legally required to verify your compliance for all three areas—WEEE, Batteries, and Packaging. A failure in one area can halt sales across the board. You must license batteries for your products separately. The complexity of managing three parallel compliance streams makes a unified strategy essential.

Understanding these duties is vital because the consequences of failure are severe and business-threatening.

The German authorities enforce the ElektroG, BattG, and VerpackG with significant penalties. Fines for failing to register can reach up to €100,000 for each violation. Authorities can also issue sales bans, preventing your products from being sold online and in physical stores. Competitors can also issue legal complaints, leading to costly court proceedings. Beyond fines, authorities can order the skimming of any profits earned while non-compliant. This means you could lose all revenue generated from illegal sales. Customs officials may also seize non-compliant goods at the border, disrupting your entire supply chain. These risks make proactive compliance a core business necessity, not just a legal formality. You must ensure legal compliance to operate securely.

Given the high stakes, delaying action is a risk most businesses cannot afford.

The complexity of German environmental laws requires immediate and expert attention. The time to act on your obligations under the EU directives is now, before your business faces disruption. Deutsche Recycling offers a complete service to manage all your EPR obligations in Germany. We handle your stiftung ear registration, act as your official Authorized Representative, and manage all ongoing reporting for ElektroG, BattG, and VerpackG. Our service guarantees 100% legal conformity, freeing you to focus on your core business. Don’t wait for a warning letter or a sales ban to force your hand. If you have not yet taken steps to comply, your market access is at risk. Contact Deutsche Recycling today for an individual consultation and secure your ability to operate in the German market without interruption.