Selling electronics in Germany – ensure WEEE compliance

If your business is selling to German customers, it’s important to ensure that you are aware of the latest regulations.

Under the German Electrical and Electronic Equipment Act (ElektroG), all producers selling electrical or electronic products must register for a Waste Electrical and Electronic Equipment (WEEE) registration number.

WEEE is one of many Extended Producer Responsibility (EPR) categories which have been implemented across the European Union as an environmental measure. 

What is Extended Producer Responsibility?

EPR refers to a set of environmental policies which have been implemented across the EU. 

It requires producers of regulated products to take responsibility for the entire lifecycle of their products, usually by registering and declaring their sales, and paying a proportional contribution fee. 

A ‘producer’ can refer to any business entity which introduces regulated products onto the market – whether they are a domestic business, manufacturer, importer or distance seller without any physical presence in the country. 

What do I need to do to comply?

Registration

If you are selling electrical or electronic products in Germany, you will be considered a producer and must register your business with the German national registry Stiftung Elektro-Altgeräte Register (Stiftung EAR). 

In addition to registering your business, you must also register for the specific WEEE subcategories which your products are classed under. 

It is important to note that if your business does not have a physical establishment in Germany, you will be required to appoint a local Authorised Representative to fulfil the registration process on your behalf, as well as any ongoing obligations. 

Subcategories

Germany has implemented the standard EU WEEE subcategorisation system which consists of the following subcategories:

• Category 1: Temperature exchange equipment
• Category 2: Screens, monitors and equipment containing screens (surface area > 100cm²)
• Category 3: Lamps
• Category 4: Large equipment (>40cm), including but not limited to – household appliances, IT and telecoms equipment, consumer equipment, musical equipment, toys and leisure appliances, sports equipment
• Category 5: Small equipment (<50cm), including but not limited to – household appliances, consumer equipment, toys and leisure appliances, sports equipment
• Category 6: Small IT and technology appliances (<50cm)

Ongoing obligations

EPR number

Once you have successfully registered with Stiftung EAR, you will be issued with a WEEE registration number.

The registration number will only be valid for use in Germany.   If you are actively trading in any other EU countries, you must check the local EPR regulations.

Online marketplaces

Under ElektroG, major online marketplaces such as Amazon are required to verify all product listings, check if they belong to any EPR categories, and ensure that sellers are registered for the relevant EPR categories and subcategories.  This includes WEEE registration numbers. 

Once you have received your WEEE registration number, you must upload it to each online marketplace and ensure that the number has been successfully verified. 

Product listings that do not have a valid EPR registration number will be automatically removed from sale. 

Usage declarations

A monthly declaration of WEEE usage is required – the declaration must detail the amount of WEEE products your business has sold in Germany.

A proportional contribution fee must then be paid based on the declaration. 

Are there any other considerations my business should be aware of?

Other EPR categories

Germany has implemented other EPR categories including Packaging, Batteries and Single-Use Plastics. 

It is important to be aware that many WEEE products will also contain batteries – in these cases, both registration numbers must be obtained before they can be sold.

Product safety

Many WEEE products will also need to undergo separate product safety testing and certification, particularly the EU CE certification scheme.  

Responsible Person

Under the General Product Safety Regulation (GPSR), non-EU businesses actively trading in an EU Member State (including Germany) will usually need to appoint a Responsible Person to comply with ongoing safety requirements.

VAT

If your business intends to store inventory in Germany, you must obtain a valid VAT registration number first.

Ongoing compliance with TBA Global

We have helped thousands of businesses expand internationally, and we are here to help you too.  Whether you need VAT, EPR, product testing or even trademarking support, we’ve got you covered. 

TBA Global is your one-stop-shop for compliance solutions – get in touch with us at info@tbaglobal.com for a free one-to-one consultation.