The German Electrical and Electronic Equipment Act (ElektroG) translates the European WEEE Directive into national law, affecting a vast range of products. This law applies to any business that first introduces electrical or electronic equipment to the German market, including importers and distance sellers. The legislation covers 6 categories of equipment, from temperature exchange equipment to small IT devices. A single non-compliant product can jeopardize your entire German sales operation. You must check if your products require registration before placing them on the market. The law mandates that producers are responsible for the entire lifecycle of their products, a principle known as Extended Producer Responsibility (EPR). Understanding this framework is the first step toward compliance.

The ElektroG defines a ‘producer’ very broadly, extending beyond traditional manufacturers. You are considered a producer if you sell electronic equipment in Germany under your own brand name. This also applies if you are the first to place a product on the German market, which includes importing goods. Even online retailers selling directly to German consumers from abroad fall under these regulations. Companies without a physical branch in Germany face specific requirements, including appointing a local representative. It is critical to understand your obligations under the ElektroG to avoid being classified as a ‘freeloader’ and facing severe penalties. This classification is key to determining your next steps in the registration process.

The official body for WEEE registration in Germany is the Stiftung Elektro-Altgeräte Register (Stiftung EAR). The entire process is managed through their online portal, where you must first create a company account. The application requires precise details about your company, brands, and the types of equipment you sell. An error in your application can extend the processing time by at least 6 weeks, delaying your market entry. The standard registration timeline already spans between 4 and 12 weeks. To successfully register with Stiftung EAR, you must provide the following information:

• Company name, address, and tax ID.
• Contact details for a legally authorized representative.
• The specific brands and equipment types for registration.
• For B2C products, proof of an insolvency-proof guarantee.
• If you are a foreign company, details of your appointed authorized representative.

This meticulous process demands accuracy to prevent costly delays.

Upon successful review of your application by Stiftung EAR, you will be issued a WEEE registration number (WEEE-Reg.-Nr.). This number, consisting of the country code ‘DE’ and an 8-digit sequence, is your license to operate in the German market. You must display this number on invoices and other business documents. Since January 2023, major online marketplaces like Amazon are legally obligated to verify this number and will delist any non-compliant products. Without a valid WEEE number, you are effectively barred from selling in Germany. The process to get a WEEE registration number is a critical business function, not just a compliance task. Once obtained, you must move to fulfill your ongoing reporting duties.

If your company does not have a physical branch in Germany, you are legally required to appoint a WEEE authorized representative. This representative must be a legal entity based in Germany and acts on your behalf to fulfill all obligations under the ElektroG. The appointment must be made in writing, in German, and be valid for a minimum of three months. The representative handles communication with authorities and ensures all reporting and take-back obligations are met. Only one authorized representative can be appointed to handle all of a producer’s brands and equipment types. Finding and appointing a reliable partner is a crucial step. You can find a WEEE authorized representative to ensure you meet this mandatory requirement without delay. This step is non-negotiable for cross-border e-commerce and sales.

Registration is not a one-time task; it marks the beginning of your ongoing compliance responsibilities. Producers must submit regular reports on the quantities of equipment they place on the market. For B2C devices, these quantity reports are due monthly. An annual report is required for both B2B and B2C equipment. Furthermore, you are responsible for financing a compliant take-back and recycling system for your products. Failure to meet these reporting deadlines can lead to fines and jeopardize your registration status. You must submit annual WEEE quantity reports accurately and on time. These duties require a robust system for tracking sales and managing data throughout the year.

The consequences of ignoring the ElektroG are severe and can halt your business activities in Germany. The German Environment Agency (UBA) can issue fines of up to €100,000 for violations such as selling unregistered equipment. Other penalties include:

1. Sales bans on all non-compliant products.
2. Confiscation of illegally earned profits.
3. Legal warnings and proceedings from competitors for unfair advantage.
4. Personal liability for company directors in some cases.

Marketplaces now enforce these rules, meaning non-compliance directly leads to a loss of sales channels. The financial and reputational risks are simply too high to ignore. It is essential to legally place electronics on the German market by adhering to all regulations from day one. Taking proactive steps is the only way to mitigate these risks.

The complexity of WEEE registration and the severe penalties for non-compliance make expert guidance essential. Deutsche Recycling offers a complete service to manage your environmental compliance obligations in Germany. We handle the entire registration process with Stiftung EAR, act as your authorized representative, and manage all ongoing reporting duties. Our service guarantees 100% legal conformity, allowing you to focus on your core business. The EU directives are clear, and enforcement is stricter than ever. You must act now to secure your business. Contact Deutsche Recycling today for an individual consultation and ensure your fast and complete compliance with all regulations.