Since January 1, 2023, a critical shift in German law directly impacts every company selling electronics online. Online marketplaces like Amazon and eBay are now legally obligated to delist any products from sellers who cannot prove their WEEE registration. This change transforms compliance from a background task into an immediate prerequisite for market access, affecting thousands of international sellers. Failure to provide a valid WEEE number now results in an automatic sales ban. This new enforcement power granted to marketplaces means your German operations can be halted with zero notice. To avoid this, you must check your EPR status immediately. This shift from spotty government checks to systematic marketplace control makes non-compliance impossible to ignore.

The German Electrical and Electronic Equipment Act (ElektroG) defines a ‘producer’ far more broadly than just a manufacturer. If you sell electronic goods to German end-users, you are almost certainly considered a producer and must comply. This definition covers at least 4 distinct business models common in e-commerce. You are considered a producer if you:

• Manufacture equipment and sell it into Germany under your own brand.
• Resell equipment from other suppliers in Germany under your own name.
• Import electronic equipment into Germany for the first time to sell it.
• Sell directly to German customers from another country (distance selling).

Many online sellers are captured by the ‘importer’ or ‘distance seller’ clauses without realizing it. Understanding your specific obligations under the ElektroG is the first step toward securing your business. This broad definition ensures that nearly every seller on a marketplace is responsible for the entire lifecycle of their products. This responsibility is not optional and requires immediate action to understand your obligations.

Companies without a physical subsidiary in Germany face a specific, non-negotiable hurdle. You cannot register with the controlling authority, stiftung ear, on your own. The ElektroG mandates that you must appoint a Germany-based Authorized Representative to manage your WEEE obligations on your behalf. This representative handles the entire registration process, submits all required reports, and acts as the legal contact point within Germany. Attempting to sell without a registered representative is a direct violation of the law. The mandate for this representative must be in writing, in German, and for a minimum of 3 months. Choosing the right partner is critical, as they are legally responsible for your compliance. You must find a WEEE authorized representative to even begin the process.

Achieving compliance involves a multi-step process with the national register, stiftung ear, that can take up to 8 weeks or more. Any errors in the application can cause significant delays and additional fees, risking your ability to sell. The core process includes these steps:

1. Create a user account in the stiftung ear online portal.
2. Provide detailed company data and designate a legal representative.
3. Register each brand and type of equipment you sell.
4. Provide an insolvency-proof financial guarantee for B2C products to cover future recycling costs.
5. Receive your unique WEEE-Reg.-Nr. DE, which you must then upload to your marketplace seller accounts.

A missing or incorrect financial guarantee is a common reason for registration failure. This complex procedure underscores the need for expert guidance to register for WEEE in Germany efficiently and correctly the first time.

While a sales suspension on Amazon is a major blow, the financial penalties for WEEE non-compliance are severe. German authorities can impose fines of up to €100,000 for failing to register correctly before selling products. Beyond fines, authorities can also order the skimming of any profits generated from the sale of non-compliant goods. The reputational damage from legal action and being marked as a non-compliant seller can impact customer trust long-term. These penalties apply per violation, meaning continued sales could lead to compounding fines. The financial and legal risks make it clear that achieving compliance is not a business choice but a necessity. You must act now to get legal compliance and protect your business from these outcomes.

The complexity of the ElektroG, the mandatory authorized representative, and the risk of €100,000 fines demand a professional solution. Attempting to manage this process alone from abroad is not just difficult; it’s often impossible. A full-service partner like Deutsche Recycling handles every aspect of your WEEE registration and ongoing obligations. We provide the mandatory authorized representative, manage the entire stiftung ear application, and ensure all reporting is completed accurately and on time. Our service guarantees 100% legal compliance, freeing you to focus on your core business. With marketplaces now enforcing these rules strictly, there is no time to waste. For sellers on platforms like Amazon, our full-service compliance is the fastest path to security. Contact Deutsche Recycling now for an individual consultation and ensure your access to the German market is not interrupted.