The Electrical and Electronic Equipment Act is being tightened. With ElektroG4, new obligations will be imposed on manufacturers, online shops, and brick-and-mortar retailers in 2026. Here is a brief overview:
❓ Who is officially considered a “manufacturer”?
Not only those who produce. Anyone who imports electrical appliances into Germany or ships them directly to end customers as a foreign retailer is also considered a manufacturer.
Important: Without registration with the ear foundation, a direct sales ban applies. Marketplaces (Amazon, eBay, etc.) must check their retailers’ EPR compliance even more strictly from 2026 onwards.
❓ What will change at recycling centers on January 1, 2026?
The counter model will become mandatory. Consumers will no longer be allowed to throw battery-powered devices into containers themselves. They must be handed over to trained staff at a reception counter. Why? The fire risk posed by incorrectly disposed lithium batteries has increased significantly.
❓ Do kiosks and gas stations now have to take back vapes?
Yes, starting July 1, 2026! Disposable e-cigarettes must be taken back free of charge at every point of sale—no matter how small the store is.
- No new purchase necessary: Customers can simply return their empty vapes.
- No exceptions: The regulation applies equally to kiosks, gas stations, and smoke shops.
❓ As a small online retailer, do I now also have to take back vapes?
Yes, from July 1, 2026, there will be no more exceptions. Anyone who sells disposable e-cigarettes must also take them back, regardless of the size of their online shop or storage space. Online retailers must also provide information on how customers can return products (e.g., by mail or via cooperation partners).
❓ What is the new take-back logo?
From July 2026, a uniform, two-color logo will be mandatory to indicate that old devices can be returned:
- Stationary: At least DIN A4 size, clearly visible (e.g., entrance).
- Online: Prominently displayed on the home page or directly in the ordering process.
- On the shelf: Large retailers must also display the symbol of the “crossed-out trash can” directly at the point of sale.
❓ Can customers now return all old appliances to the supermarket?
Supermarkets, discount stores, and drugstores with a sales area of more than 800 m² that regularly sell electrical appliances must take back old appliances with a maximum edge length of 25 cm free of charge. This applies regardless of whether a new purchase is made.
Important: The plan to raise this limit to 50 cm (for microwaves, etc.) was deleted in ElektroG4. For the time being, everything remains as it was.
❓ Does the 25 cm rule also apply to B2B appliances?
No. The free return of small appliances without a new purchase primarily applies to old appliances from private households (or comparable quantities from businesses). In the pure B2B sector, individual disposal agreements between manufacturers and customers often remain in place, but must be communicated more clearly in the ElektroG4 presentation media.
❓ What new information requirements do manufacturers have?
From 2026, manufacturers will have to provide much more detailed information:
- Hazards: Manufacturers must provide more detailed information about the risks posed by lithium batteries.
Removal: Clear instructions must be provided on how to remove old batteries, rechargeable batteries, and lamps before disposal. This applies to devices in which the batteries are not permanently installed.
Quotas: Manufacturers are required to make information about the take-back and recycling quotas for their products publicly available on their own websites.
B2B: Manufacturers must ensure that business customers are also informed about proper disposal and that take-back solutions are provided.
❓ Will there be a deposit on batteries or a ban on vapes?
Not yet. Although waste disposal companies and local authorities have called for a battery deposit and a ban on disposable vapes, legislators have not (yet) implemented this in the ElektroG4. However, the issue of vapes is to be reassessed from 2026.
❓ Am I still allowed to sell electrical devices with permanently installed batteries?
The ElektroG4 alone does not prohibit them, but the EU Battery Regulation applies in parallel: From 2027, batteries in most devices for end users must be easily removable and replaceable. The ElektroG4 supplements this with stricter information requirements regarding removal at the point of sale.
❓ What happens if the Electrical and Electronic Equipment Act (ElektroG) is not complied with?
The risk is high:
- Fines: Up to €100,000.
- Warnings: Competitors can issue costly warnings for a lack of take-back options or incorrect labeling.
- Profit skimming: Illegally generated sales without ear registration can be confiscated.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
Contact: www.ecopv-eu.com/kontakt | Email: info@ecopv-eu.com
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