FAQs

• manufactures and markets products under its own name or trademark)
• designs or commissions the manufacturing of products and markets them under its own name or trademark
• resells products from another producer under its own name or trademark (unless the original brand remains visible))
• places products from abroad on the German market for the first time
• offers products directly to end users in Germany via distance sales contract, while being established in another EU Member State or a third country

Distributors who intentionally or negligently resell non-registered products are classified as producers as well.

Any company that qualifies as a producer under the ElektroG is required to register. This includes any entity that places electrical or electronic equipment on the market for the first time in Germany.

Placing on the market means making products available — whether for payment or free of charge — for distribution or use in the course of a business activity. Reimports are also considered placing on the market.

As a producer without legal establishent in a given country, you are in many cases only permitted to place electrical equipment, batteries, or packaging on the market if you appoint an authorised representative established in that country. This representative assumes clearly defined obligations vis-à-vis the competent authorities and acts as your legal point of contact.

If you are a producer without legal establishment in Germany, BattDG and ElektroG oblige you to appoint an authorised representative. The authorised representative assumes your legal obligations in Germany and ensures compliance with all applicable regulatory requirements.

As part of our registration services, we support you by coordinating the necessary contacts and documentation for authorised representatives in the respective country. For specific questions, please contact compliance@bitkom-consult.de

stiftung ear is the Joint Body of Producers within the meaning of the Elektro- und Elektronikgerätegesetz (ElektroG) and the Batterieverordnungsdurchführungsgesetz (BattDG). It is responsible for registering producers of electrical equipment and batteries and for coordinating collection and take-back activities across Germany. Further information is available here or at www.stiftung-ear.de

Producers are required to comply with a number of obligations, including:

• Registration with stiftung ear and application for a WEEE number. The WEEE number is a unique identification number issued by stiftung ear in Germany. It is required for producers of electrical and electronic equipment within the scope of the ElektroG in order to place their products on the German market.
• Provision of an insolvency-proof guarantee for B2C equipment.
• For producers without legal establishment in Germany, appointment of an authorised representative who fulfills all regulatory obligations on their behalf in accordance with German law.
• Submission of declaration of credibility and take-back concept for B2B equipment. As part of this process, producers must clearly and plausibly demonstrate to stiftung ear why their equipment qualifies as B2B.
• Regular reporting of quantities placed on the market:
• Ensuring environmentally sound disposal and proper recycling.

The registration process is a formal administrative procedure under public law. It begins with the submission of the registration application. Responsibility for the application lies with your company.

For electrical equipment and batteries, registration is completed via the stiftung ear portal, where key product and brand information must be provided. If all requirements are met, the authority issues a registration decision, including your WEEE or battery Batt number.

Packaging registration is handled via the LUCID register maintained by Stiftung Zentrale Stelle Verpackungsregister.

For support with the registration process, please contact us via our contact form.

The statutory processing period for registration applications with stiftung ear and the Central Agency Packaging Register is up to 12 weeks. In practice, authorities may use the full timeframe, although processing times are often shorter.

Delays are typically caused by incomplete or inconsistent applications. Submitting accurate and complete information from the outset is therefore essential. To avoid any disruption to your market entry, we recommend initiating the registration process well in advance of placing electrical and electronic equipment, batteries, or packaged products on the German market.

Eco-modulation links EPR fees to product characteristics. Products that are easier to recycle, repair, or contain a higher share of recycled materials typically benefit from reduced fees, while products that are difficult to recycle or contain hazardous substances are subject to higher charges.

Eco-modulation has been in place in some countries for several years. Recent EU initiatives, including the PPWR, are driving a broader and more standardised application, using financial incentives to encourage more sustainable product design.

As a producer without legal establishent in a given country, you are in many cases only permitted to place electrical equipment, batteries, or packaging on the market if you appoint an authorised representative established in that country. This representative assumes clearly defined obligations vis-à-vis the competent authorities and acts as your legal point of contact.

If you are a producer without legal establishment in Germany, BattDG and ElektroG oblige you to appoint an authorised representative. The authorised representative assumes your legal obligations in Germany and ensures compliance with all applicable regulatory requirements.

As part of our registration services, we support you by coordinating the necessary contacts and documentation for authorised representatives in the respective country. For specific questions, please contact compliance@bitkom-consult.de

stiftung ear is the Joint Body of Producers within the meaning of the Elektro- und Elektronikgerätegesetz (ElektroG) and the Batterieverordnungsdurchführungsgesetz (BattDG). It is responsible for registering producers of electrical equipment and batteries and for coordinating collection and take-back activities across Germany. Further information is available here or at www.stiftung-ear.de

Producers are subject to a range of obligations under German battery law. This includes, in particular, the requirement to register with stiftung ear and obtain a registration number. This number serves as a unique identifier issued in Germany and is mandatory for producers and distributors of batteries in order to place their products on the German market.

In addition, producers must ensure the proper collection and disposal of batteries. Depending on the battery category, they may fulfil these obligations by joining a producer responsibility organisation.

Producers are also required to comply with labelling requirements. Under the BattVO, this includes not only the crossed-out wheeled bin symbol but also additional markings, such as CE marking, where applicable.

What obligations do producers have under the BattDG?

Under the Batterieverordnungsdurchführungsgesetz (BattDG), producers are subject to several key obligations. These include, in particular, the requirement to register with stiftung ear before placing batteries on the German market. As part of this process, producers must obtain a registration number, which serves as proof of compliance and is required for market access.

Producers are also responsible for ensuring the proper collection and environmentally sound disposal of batteries. This obligation can typically be fulfilled by participating in a producer responsibility organisation, depending on the battery category.

In addition, producers must comply with applicable labelling requirements. These include the crossed-out wheeled bin symbol as well as further markings, such as CE marking, where relevant.

Finally, producers are required to meet ongoing obligations, including reporting and ensuring that all regulatory requirements are continuously fulfilled.

The registration process is a formal administrative procedure under public law. It begins with the submission of the registration application. Responsibility for the application lies with your company.

For electrical equipment and batteries, registration is completed via the stiftung ear portal, where key product and brand information must be provided. If all requirements are met, the authority issues a registration decision, including your WEEE or battery Batt number.

Packaging registration is handled via the LUCID register maintained by Stiftung Zentrale Stelle Verpackungsregister.

For support with the registration process, please contact us via our contact form.

The statutory processing period for registration applications with stiftung ear and the Central Agency Packaging Register is up to 12 weeks. In practice, authorities may use the full timeframe, although processing times are often shorter.

Delays are typically caused by incomplete or inconsistent applications. Submitting accurate and complete information from the outset is therefore essential. To avoid any disruption to your market entry, we recommend initiating the registration process well in advance of placing electrical and electronic equipment, batteries, or packaged products on the German market.

Eco-modulation links EPR fees to product characteristics. Products that are easier to recycle, repair, or contain a higher share of recycled materials typically benefit from reduced fees, while products that are difficult to recycle or contain hazardous substances are subject to higher charges.

Eco-modulation has been in place in some countries for several years. Recent EU initiatives, including the PPWR, are driving a broader and more standardised application, using financial incentives to encourage more sustainable product design.

Any company that qualifies as a producer under the VerpackG must register in the LUCID Packaging Register. This applies to all companies that place packaging on the German market for the first time on a commercial basis where the packaging typically becomes waste in Germany. Registered producers are also required to submit regular quantity reports.

As a producer without legal establishent in a given country, you are in many cases only permitted to place electrical equipment, batteries, or packaging on the market if you appoint an authorised representative established in that country. This representative assumes clearly defined obligations vis-à-vis the competent authorities and acts as your legal point of contact.

companies that place packaging on the market in Germany for the first time are required to assume financial responsibility for its collection and recycling. This applies in particular to filled or unfilled sales and secondary packaging, primary production packaging, transport packaging that typically becomes waste in private households or comparable sources, as well as service packaging.

The obligation to participate in a collective system and to contribute to the financing of collection and recycling through that system is referred to as Systembeteiligungspflicht.

The registration process is a formal administrative procedure under public law. It begins with the submission of the registration application. Responsibility for the application lies with your company.

For electrical equipment and batteries, registration is completed via the stiftung ear portal, where key product and brand information must be provided. If all requirements are met, the authority issues a registration decision, including your WEEE or battery Batt number.

Packaging registration is handled via the LUCID register maintained by Stiftung Zentrale Stelle Verpackungsregister.

For support with the registration process, please contact us via our contact form.

The statutory processing period for registration applications with stiftung ear and the Central Agency Packaging Register is up to 12 weeks. In practice, authorities may use the full timeframe, although processing times are often shorter.

Delays are typically caused by incomplete or inconsistent applications. Submitting accurate and complete information from the outset is therefore essential. To avoid any disruption to your market entry, we recommend initiating the registration process well in advance of placing electrical and electronic equipment, batteries, or packaged products on the German market.

Eco-modulation links EPR fees to product characteristics. Products that are easier to recycle, repair, or contain a higher share of recycled materials typically benefit from reduced fees, while products that are difficult to recycle or contain hazardous substances are subject to higher charges.

Eco-modulation has been in place in some countries for several years. Recent EU initiatives, including the PPWR, are driving a broader and more standardised application, using financial incentives to encourage more sustainable product design.

The new textile EPR requirements apply to producers, retailers, and importers of textiles, footwear, and similar products placed on the market.

Any company that sells products in a Member State or places them on the market there for the first time must assess and comply with the applicable national requirements.

Producers are subject to several core obligations under the new textile EPR framework. These include registering with the relevant national authority and submitting regular reports, for example on volumes and material types.

In addition, producers are required to contribute to or finance the collection, sorting, and recycling of textile waste. This is typically done through fees, which are generally calculated based on the quantities placed on the market.

Fees are generally based on the quantities placed on the market, typically measured by weight (kg) per material category and national product group.

Eco-modulation links EPR fees to product characteristics. Products that are easier to recycle, repair, or contain a higher share of recycled materials typically benefit from reduced fees, while products that are difficult to recycle or contain hazardous substances are subject to higher charges.

Eco-modulation has been in place in some countries for several years. Recent EU initiatives, including the PPWR, are driving a broader and more standardised application, using financial incentives to encourage more sustainable product design.