Photovoltaic (PV) modules are among the most sustainable energy sources, but once they reach the end of their life, they become resource-relevant waste. Manufacturers and distributors therefore carry not only product responsibility but also extended producer responsibility. This includes proper disposal as well as the obligation to register PV modules and their components.
Registration Requirements under the Electrical Equipment Act (ElektroG)
Since the introduction of the Electrical Equipment Act (ElektroG), all manufacturers of electrical and electronic devices must register their products with the Stiftung Elektro-Altgeräte Register (stiftung ear). PV modules have been included under this regulation since October 24, 2015.
Failing to register can result in fines and legal warnings—ignorance is no defense. The stiftung ear acts as a central authority for manufacturers, coordinating collection, take-back, and recycling of electrical devices.
New from 2025: ZEREZ – Central Register for Units and Component Certificates
Starting February 1, 2025, a new obligation applies:
- Manufacturers of PV components (e.g., modules, inverters, storage systems) must register their products in ZEREZ and obtain a ZEREZ ID.
- Without this ID, new PV systems cannot be connected to the grid.
- Operators of PV systems must ensure that only ZEREZ-certified components are used for new installations or replacements.
Exceptions: Small balcony systems are partially exempt (e.g., ≤ 2 kW output, inverters ≤ 800 VA). Autonomous systems without any connection to the public grid do not require registration.
Recycling Quotas and Obligations
Under the EU WEEE Directive (2012/19/EU), the following rules still apply:
- 85% of old modules must be collected.
- 80% of materials must be returned to the recycling stream.
- Manufacturers must provide a functional take-back system and meet these recycling targets.
PV modules are considered “dual-use” devices and must be registered as B2C products, regardless of the sales channel, so that collection through municipal recycling centers is ensured.
Other Legal Updates (EEG 2023, Solar Package I & II, Solar Peak Act)
In addition to ElektroG and ZEREZ, the following updates apply:
- Faster grid connection processes
- Expansion of the tenant electricity model
- Balcony systems no longer require registration with the grid operator, but registration with the Market Master Data Register (MaStR) is still required
- Same feed-in tariff applies when replacing old modules
- More open spaces allocated for solar parks
- Feed-in for balcony systems increased from 600 to 800 watts
- More flexible direct marketing of solar electricity
Practical Consequences of Non-Compliance
- No grid connection: Systems without a valid ZEREZ ID will not be commissioned.
- Fines: Violating ElektroG or the WEEE Directive can be costly.
- Reputation risk: Non-compliance can result in warnings and damage to your brand’s reputation.
Support from Deutsche Recycling
Keeping track of all these regulations can be challenging. Deutsche Recycling GmbH helps you meet your obligations efficiently and in full compliance—from registering with stiftung ear, documenting recycling certificates, and setting up take-back systems to ensuring compliance with all national and international recycling laws.
Contact us today to ensure that your PV products can be legally placed on the market from 2026 onwards.
