Anyone who manufactures electrical appliances in Germany, imports them into Germany, or offers them for sale here for the first time cannot avoid it: the WEEE registration number. Despite the strict legal requirements of the ElektroG, many market participants underestimate or overlook this obligation – with consequences that can sometimes threaten their very existence.
What’s behind this?
WEEE stands for “Waste of Electrical and Electronic Equipment.” In Germany, the Electrical and Electronic Equipment Act (ElektroG) implements the corresponding EU directive. Every first-time distributor must register with the EAR Foundation. Devices may only be legally sold after receiving the WEEE number.
Which products must be registered?
All devices designed to operate on alternating current (max. 1,000 V) or direct current (max. 1,500 V) are subject to mandatory registration. Important to understand: The WEEE number is a company-specific identification number. This means you do not receive a new number for each product, but rather register your brand and the respective device type once.
A legal distinction is made between B2C (for private use) and B2B (purely commercial). This classification is crucial, as significantly stricter requirements apply to B2C devices: Here, manufacturers must provide an insolvency-proof guarantee annually. This ensures that the disposal of end-of-life equipment is financially secured, even if the company goes out of business.
What about different brands and device types?
- Single number: As a company, you receive only one WEEE-ID from the EAR Foundation, which identifies you as a market participant.
- Additional registrations: Although the number remains the same, each combination of brand and device type must be registered separately.
- Important: The sale of a brand or device type that is not explicitly registered under your number is legally considered unregistered.
Who is affected?
- Manufacturers: Those who produce or commission the design of products under their own name or brand.
- Importers: Those who bring devices from abroad (whether from the EU or non-EU countries) into Germany and offer them for sale here for the first time.
- Online direct sellers: Those who ship goods directly from abroad to German end consumers (an authorized representative is often required in this case).
- Retailers / Resellers: If you offer devices whose actual manufacturers are not properly registered (assumption of manufacturer liability).
- Small business owners: The obligation applies starting with the first device – there are no minimum quantities or de minimis thresholds.
Here’s how registration works
Registration takes place online via the EAR Foundation’s portal:
- Account creation: Create a user account and enter company details.
- Classification: Specify the brand and the specific device type (e.g., small appliances, monitors, lamps).
- Proof of warranty (B2C only): Provide an insolvency-proof warranty (e.g., via a surety system or a collective service provider).
- Take-back plan (B2B only): Proof of how disposal in the commercial sector is ensured.
- Review & fees: After submitting the application, a fee notice is issued; the review begins only after payment is received.
If the equipment is complete, processing typically takes 2 to 4 weeks – though it may take significantly longer if there is a high volume of applications. No appliance may be sold until the number has been issued.
⚠️ What are the consequences of non-compliance?
- Fines: The competent authority (UBA) may impose fines of up to 100,000 euros per violation.
- Sales ban & platform suspension: Marketplaces such as Amazon, eBay, or Otto are legally required to immediately suspend sellers without a valid WEEE number.
- Warnings: Since the EAR Foundation’s WEEE register is publicly accessible, competitors and associations actively use this to issue costly warnings under competition law.
- Profit confiscation: In addition to fines, authorities can claim all revenue generated from unregistered devices.
- Take-back obligation: In this case, the authority can order the recall of all devices already sold from end consumers at your expense.
Where must the number be displayed?
According to § 6(3) of the ElektroG, every registered manufacturer or authorized representative is required to include their WEEE number when offering devices for sale and on invoices. To avoid warnings, the number should be clearly visible in the following places:
- Sales platforms: Entered in the backend of Amazon, eBay, etc. (required for activation).
- Invoices: Mandatory inclusion in the header or footer.
- Imprint: Legally compliant information on the website (e.g., “WEEE Reg. No. DE 12345678”).
- Business documents: Delivery notes, order confirmations, and quotes.
- Marketing materials: In catalogs or price lists where products are directly offered.
🌍 Selling across the EU? A separate number for each country.
A German WEEE number is not valid throughout the EU. Since the WEEE Directive is implemented individually by each EU member state, companies that sell internationally must register separately in each target market. If your company does not have a legal seat in the target country, the law in almost all EU states requires the appointment of a local authorized representative. This representative assumes legal responsibility and fulfills reporting obligations on your behalf locally.
How does ECOPV-EU assist you with the WEEE number?
Whether you operate in the B2B or B2C sector or your company is based abroad—we at ECOPV-EU are happy to assist affected manufacturers in obtaining the WEEE number. Our services cover the entire process, from registration to the labeling of your electrical and electronic equipment. Rely on ECOPV to efficiently meet the legal requirements related to the WEEE number.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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