Anyone who places electrical or electronic equipment on the market in Germany is required by the ElektroG to register with the EAR Foundation. This obligation applies not only to manufacturers but also to importers and retailers who sell equipment under their own brand name – and are therefore legally considered manufacturers.
The key factor here is correct device categorization. Every device must be assigned to one of the six WEEE categories – take-back obligations, volume reporting, and disposal costs depend on this.
Who is affected?
Manufacturers based in Germany, importers, and authorized representatives of foreign manufacturers, as well as retailers who sell devices without a verifiably registered manufacturer.
The Six WEEE Categories
Cat. 1 – Heat Exchangers: Appliances with an integrated circuit (refrigerants, oils, gases) for cooling, heating, or dehumidification – e.g., refrigerators, air conditioners, heat pumps.
Cat. 2 – Screens & Displays: Devices for image display with a screen area > 100 cm² – e.g., televisions, monitors, laptops.
Cat. 3 – Lamps: Light sources for generating light with a standardized base (E27, GU10) – including smart lamps. Not included: the light fixture itself.
Cat. 4 – Large appliances (> 50 cm): Devices where at least one dimension exceeds 50 cm – e.g., washing machines, large PV modules (B2C).
Cat. 5 – Small appliances (≤ 50 cm): Devices under 50 cm that do not fall under Categories 1–4 or 6 – e.g., small household appliances, tools, small PV modules.
Cat. 6 – Small IT & telecommunications devices: Devices for information capture, transmission, or storage under 50 cm – e.g., smartphones, tablets, routers.
Exceptions, and therefore not covered, include:
- Military equipment (weapons, ammunition, armed forces)
- Traditional incandescent bulbs (tungsten filament – not LED, not halogen)
- Space equipment
- Large stationary industrial tools
- Large stationary industrial systems
- Vehicles (Exception: registration-exempt electric two-wheelers are still covered by the ElektroG)
- Mobile machinery
- Devices used exclusively for research and development at the inter-company level
- Permanently installed parts in devices already exempted
- Medical devices posing an infection risk before the end of their service life
- Active implantable medical devices
Not sure where your device belongs?
We review each case individually, classify it in accordance with the law, and, upon request, handle the complete EPR registration with the EAR Foundation – for Germany and other EU markets.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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