TBA Global

EPR Registration in Germany

EPR in Germany

Are you affected by EPR regulations as a seller or manufacturer in Germany?​

EPR, or Extended Producer Responsibility, is a key environmental concept in Germany. In a nutshell, EPR compliance mandates that producers take responsibility for the entire life cycle of their products, from manufacturing to disposal. In Germany, this means that companies are legally obligated to manage the recycling and proper disposal of the products they introduce into the market.

EPR Categories in Spain​

Important Update: Germany Introduces EPR for Single-Use Plastics in 2025

Starting from the 1st January 2025, a new Extended Producer Responsibility (EPR) category will be enforced in Germany – Single-Use Plastics (SUPs).  Registration for non-German businesses will not be available until August 2024.

This category was created by Single-Use Plastics Fund Act (EWKFondsG).  SUPs will join the three existing categories (Packaging, Batteries and WEEE). 

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Germany EPR Requirements for Online Sellers

Germany EPR Requirements for Online Sellers​

Packaging

To comply with EPR regulations as an online seller of Packaging in Germany, you must:

Register

With the Central Agency Packaging Register before you sell any packaged goods on the German market.

Join a PRO

Any packaging you place on the market must be licensed with a PRO.

Report

The packaging quantities you place on the German market to both the Central Agency (LUCID Platform) and the PRO.
You must submit your reporting in kg (kilograms) per material types.

Waste of Electrical and Electronic Equipment (WEEE)

To comply with EPR regulations as an online seller of WEEE & EEE in Germany, you must:

Authorised Representative

If you are a manufacturer or dealer of electrical and electronic equipment without a subsidiary in Germany, you must appoint an authorized representative.

Register

Your electrical devices with the registry (per category and per brand).

Join a PRO

To ensure collection and recycling of electrical and electronic equipment.

Report

The quantities of WEEE placed on the German market. You must submit your reporting in kg (kilograms) per material types

Batteries

To comply with EPR regulations as an online seller of Batteries in Germany, you must:

Authorised Representative

If you do not have a subsidiary in Germany, you must appoint an authorized representative.

Register

With the registry (per battery type and per brand).

Join a PRO

Membership must be approved by the scheme during the registration process.

Report

How Do I Prove EPR Compliance in Germany? 

The quantities of batteries placed on the German market. You must submit your reporting in kg (kilograms) per material types.

In addition to joining a PRO, you also need to submit the EPR registration number(s). To get this number, you need to register with the relevant EPR registry. Once you receive your EPR registration number(s), you can provide it to your Marketplace as proof of compliance.

Step

Register with EPR

Step

Communicate the registration to Marketplac as proof of compliance

Step

Packaging: ZSVR registration number

EEE: WEEE-Reg.-Nr. (WEEE number consists of prefix
DE for Germany + 8 digits; i.e. DE12345678)

Battery: Batt-Reg.-Nr. as proof of compliance (e.g., DE12345678). Note: In Germany, if you offer an EEE product containing a battery, you must register for both EEE and Batteries.

Effortless Compliance with TBA Global

Free Consultation

Book a consultation
for free.

Join TBA Global

You sign contract
with TBA Global.

Registration

We register you
with our systems.

Contract Management

We take care of
all the bureaucracy.

Declaration & Reporting

You declare all
your quantities via
our portal.

Frequently Asked Questions

While EU countries adhere to EU regulations regarding EPR, each country has its own policies and requirements. Therefore, EPR numbers cannot be shared with other EU countries.

You can find clear instructions and examples of categories provided by a German recycling company through the following link:

https://www.stiftung-ear.de/en/topics/elektrog/producers-ar/allocating-equipment

According to EPR regulations, a ‘producer’ is defined as the entity that first introduces a product covered by EPR provisions onto the domestic market. This includes merchants who:

  • Package and place products on the market
  • Source packaging, electrical appliances, or batteries from a manufacturer and distribute them to consumers
  • Import packaging, electrical appliances, or batteries
  • Sell packaging, electrical appliances, or batteries without being domiciled themselves

Changes to German packaging and electrical waste legislation have imposed control duties on marketplaces such as Amazon and eBay. Consequently, operators are now restricting their marketplaces to sellers who can demonstrate compliance with EPR regulations. Therefore, you will need to add/upload your EPR documentation to your seller account. Proof for packaging was required by July 2022, for electrical appliances by January 2023, and for single-use plastics (SUP) by January 2025.

Compliance with EU Extended Producer Responsibility (EPR) regulations is essential. Producers are legally obligated to comply if they meet the criteria outlined by EU regulations and the specific policies of each country. For reference, you can review Amazon’s EPR FAQs and adapt the information to fit your needs.
https://sellercentral-europe.amazon.com/help/hub/reference/external/GYDCAK9ZR6VJH2X3?locale=en-GB

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