PV-Panels​:
PV Modules & Photovoltaics: Compliance Requirements for Solar Energy

Yes. In Germany, photovoltaic modules are considered electrical and electronic equipment. Anyone who imports PV modules into the German market or sells them under their own brand must be registered with the EAR Foundation.

The WEEE requirements for solar modules serve to ensure the long-term availability of raw materials such as silicon, silver, and copper, as well as their environmentally sound disposal at the end of their life cycle. First-time distributors are subject to the same obligations as traditional electronics manufacturers: They must apply for a WEEE number, submit monthly volume reports, and participate in the nationwide collection coordination program. This legal requirement applies regardless of the distribution channel – that is, it applies equally to B2B wholesale and to direct sales via e-commerce.

PV modules and inverters fall under the ElektroG and each require their own WEEE registrations with the EAR Foundation. Battery storage systems, on the other hand, are primarily subject to the Battery Implementation Act (BattDG) and the EU Battery Regulation.

Anyone who sells complete solar systems, including storage systems, must fulfill several statutory registration and reporting requirements simultaneously. Inverters and modules are classified as separate electrical devices. The associated battery storage systems require separate battery registration as well as affiliation with a take-back system for industrial batteries. Full-service providers such as ECOPV-EU consolidate these parallel EPR obligations for solar providers to minimize the bureaucratic burden.

Standard photovoltaic modules are classified in Category 4 (large appliances with at least one external dimension exceeding 50 cm) in the EAR system. Legally, they are considered “dual-use” products, which triggers the requirement to provide an insolvency-proof guarantee.

Since solar modules can be used both on private residential rooftops and in commercial solar farms, the EAR Foundation generally classifies them as B2C devices (“dual-use”). Only in very rare exceptional cases – when modules are designed exclusively for large-scale industrial power plants and can be proven to be used only there – is a pure B2B classification without a guarantee requirement possible. For balcony power plants or portable solar kits, Category 5 (small appliances) may also apply on a case-by-case basis, depending on their dimensions. An incorrect classification leads to miscalculations in collection orders and guarantee amounts.

The core WEEE obligations for solar modules remain essentially unchanged. However, the inspection requirements for online marketplaces that took effect with ElektroG4, as well as the stricter information requirements for PV systems with battery storage, are having a significant impact.

Since balcony power plants and solar modules are increasingly sold through e-commerce platforms, the fully automated WEEE monitoring of these marketplaces now applies. Without exact compliance with registration requirements, PV listings are immediately blocked. In addition, the new legal disclosure requirements regarding lithium-ion batteries apply to PV providers as soon as they sell complete sets that include battery storage. Since then, retailers have been required to provide consumers with significantly more detailed information about fire risks and the proper disposal procedures for used batteries.

Registration is done digitally via the EAR manufacturer portal by providing company information, the brand, and the projected sales volumes. For standard classification as a B2C device, it is mandatory to provide an insolvency-proof guarantee.

The application requires a precise product classification based on dimensions and intended use. The EAR Foundation will not issue the WEEE registration number until the proof of financial guarantee in the event of subsequent insolvency has been thoroughly reviewed and approved. Since the processing time for solar components often takes several weeks to months, and distribution without a registration number is illegal, the application must be submitted well in advance of the planned market launch. Many solar companies use full-service providers for this purpose to avoid errors in the complicated volume forecasting process.

A manufacturer is defined as the party that first makes PV modules available on the German market. Anyone who imports solar modules from a non-EU country (e.g., China) into Germany is legally considered the first distributor and assumes full manufacturer responsibility.

The legal definition makes a strict distinction between physical manufacturing and market introduction. The importer is liable for all obligations: They must complete WEEE registration, finance the insolvency-proof warranty, and submit monthly volume reports. If, on the other hand, a retailer purchases the modules from a wholesaler already registered in Germany, these obligations do not apply to the retailer. Foreign module manufacturers without a German registered office that deliver directly to German customers are required to appoint a domestic authorized representative.

Generally, no. If you purchase modules that are already properly registered from a manufacturer or wholesaler and install them in Germany, the upstream supplier assumes responsibility for the WEEE obligations.

The situation becomes more complicated with direct imports: If, as a small business, you source modules directly from a non-EU country (e.g., China) or distribute brands from unregistered suppliers, you legally become the manufacturer yourself. In this case, you must complete the initial registration with the EAR Foundation, report monthly quantities, and provide guarantees. Therefore, it is mandatory to check the WEEE number in the EAR register before changing suppliers.

Each EU member state implements the WEEE Directive through its own laws. Registration with the German EAR Foundation applies exclusively to the German market; separate, national registrations must be completed for exports to other EU countries.

For solar companies operating internationally, this entails a significant administrative burden. Fees, reporting deadlines, and warranty models vary widely from country to country. In addition, nearly all countries require the appointment of a national authorized representative if the company does not have a local registered office. EPR service providers consolidate these processes across national borders to avoid maintaining parallel individual structures.