Relatively soon after the 2018 revision of the German Electrical and Electronic Equipment Act (ElektroG), the next change is already approaching. With the 2019 WEEE Directive, EU member states are required to adapt their national laws to harmonize the handling of electrical and electronic equipment across the EU. As a result, many regulations in international trade now apply uniformly throughout Europe, making cross-border goods movement easier.
Update to the Electrical Equipment Act: Passive Devices
Since May 2019, the WEEE Directive in Germany specifically concerns the registration requirement for passive, current-carrying devices.
- Effective from May 2019: Passive devices such as charging cables have been subject to the registration requirement since 01.05.2019.
- Mandatory registration: Devices must be registered with the stiftung ear.
- Already in other EU countries: Some EU countries implemented this change as early as 2018.
- Risk of fines: Missing or incorrect registration can lead to warnings under the Electrical Equipment Act and substantial fines.
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What are passive devices and when are they covered by the ElektroG?
Passive devices are end devices that conduct electricity but do not themselves process it. They are divided into end devices and components.
End devices are independent and can be used on their own. They are usually available in retail and can be used and replaced by non-professionals. Examples include extension cords, antennas, light switches, and sockets.
Components, on the other hand, are not independent. They can only be used if integrated into another product. Examples include bulk cables, ferrules, and ring terminals. Components are not covered by the ElektroG under the 2019 WEEE Directive and therefore do not require registration.
Passive devices that are also end devices have been classified as electrical and electronic equipment since 2019, meaning the ElektroG applies. These devices are categorized in categories 4–6 as either:
- Large devices with external dimensions over 50 cm
- Small devices with external dimensions under 50 cm
- Small information and communication technology devices
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Which passive devices are covered by the ElektroG and WEEE Directive since 2019?
The following end devices (passive devices) have been subject to participation requirements since 01.05.2019:
- Antennas (e.g., outdoor and rooftop antennas, rod and telescopic antennas, whip antennas, and indoor antennas)
- Adapters (e.g., HDMI adapters, USB adapters, audio jack adapters, travel plugs, telephone adapters, and plug-in adapters)
- Fixed mounting sockets (e.g., antenna sockets, industrial and high-current sockets, telephone sockets and outlets)
- Cables (e.g., audio cables, HDMI cables, USB cables and extensions, amplifier cables, extension cords, and cable reels)
- Light switches and emergency switches for fixed installation
- Fuses (standard and fine)
Ring terminals, bulk cables, and ferrules are not considered electrical devices under the 2019 WEEE Directive due to their low voltage. They do not require registration, and used products do not need to be registered again.
WEEE Directive 2019: Who is affected by the change in the ElektroG?
The change affects all parties considered manufacturers. Manufacturers are not only companies that produce electrical devices themselves, but also those who first place devices on the German market, including importers. Anyone branding passive devices such as USB sticks, charging cables, or memory cards with their own name or logo (e.g., as promotional items) is considered a manufacturer and must register these products.
Distributors and Take-Back Obligations
If you purchase products from other brands for resale, you are a distributor. Registration is not required if the original manufacturer has already registered the devices. Exception: For sales areas of at least 400 square meters, there is an additional obligation to accept old devices.
What information must I provide when registering?
Registering electrical devices with stiftung ear can be somewhat complex. In addition to the manufacturer’s name and address, foreign manufacturers must also provide details of their authorized representative. Additionally, the national manufacturer number, as well as national and international tax numbers, must be included. Further information about the device (type, brand, and device category), individual or collective system coverage, and planned sales method must also be provided.
If you have questions or are unsure which of your devices fall under the new sections of the ElektroG, contact us! We provide solutions for manufacturers and distributors, taking care of the entire registration process on your behalf.
WEEE Directive 2019
Do I need to provide device registration before placing products on the market?
Yes, the registration requirement under the ElektroG must be fulfilled before market launch. Only after registration with stiftung ear and receipt of a registration number may electrical devices be offered or advertised for sale in Germany.
What happens if products are later classified as passive electrical devices?
If your products are later classified as subject to registration due to changes in legal interpretation or market developments, you must register them immediately. Negligent manufacturers risk sales bans and fines.
The registration requirement cannot generally be transferred to suppliers or other third parties if you are the first distributor in Germany. However, you can appoint authorized representatives under §8 ElektroG to act on your behalf—but legal responsibility remains with you.
Compliance is monitored through random inspections, targeted inquiries, and cross-checking your reports with stiftung ear. Violations can result in fines and warnings.
