The Electrical and Electronic Equipment Act (ElektroG) regulates the environmentally sound disposal of electrical and electronic equipment. Since the ElektroG4 amendment, which took effect on January 1, 2026, new take-back and information obligations have also applied to retailers.
Take-back obligations based on sales area
- For total sales areas of 800 m² or more: Food retailers (discounters, supermarkets) that regularly sell electrical appliances are required to accept returns.
- For sales areas of 400 m² or more dedicated to electrical appliances: This obligation applies to all other retailers with corresponding sales areas for electrical appliances.
- Online and mail-order retailers: Same principle as in stationary retail: Retailers with at least 400 m² of storage and shipping space for electrical appliances must accept old devices and offer a reasonable return option for consumers.
- New: As of July 1, 2026, the space requirement for e-cigarettes will be completely eliminated. This means: Every kiosk, gas station, and small shop that sells vapes must also accept them for return free of charge – regardless of how small the store is and without requiring a new purchase.
- Important: Starting in July 2026, the new standardized collection point logo (green plug) must also be prominently displayed in online stores to indicate the return option.
New collection point logo
Type of Take-Back
- Small appliances (≤ 25 cm edge length): Free of charge, regardless of whether a new purchase is made (up to 3 units per appliance type) → so-called “0:1” take-back.
- Large appliances: Only when a new, similar appliance is purchased (“1:1” take-back). The retailer must accept the old appliance free of charge or take it back upon delivery. In the future, the retailer must use the new collection point logo (green plug) to indicate this.
Retailer obligations
- Returns must be free of charge.
- Retailers must publicly inform customers about the return option.
- Upon delivery of a new large appliance, the old appliance must be taken back upon request.
- Section 17 of the ElektroG stipulates: Return must be possible “in or in the immediate vicinity of the store” or, in the case of online retailers, within a “reasonable distance.”
- Starting in 2026, a documentation requirement will also apply: Retailers must more accurately record the number of devices taken back and report this to the EAR Foundation to increase transparency regarding collection rates.
Practical Challenges
- Hazardous Waste: Devices such as old energy-saving light bulbs contain mercury and are classified as hazardous waste. They must be collected in special containers designed to prevent breakage.
- Old devices with lithium batteries: These are considered hazardous materials due to the risk of fire and explosion. Since the ElektroG4 amendment, retailers must ensure that batteries (if removable) are stored separately from the device. Damaged batteries are classified as high-hazard materials and require special fire-resistant containers.
- Online retail: A free pickup directly from the end consumer without a new purchase (0:1) is not required by law. The online retailer must only ensure a “reasonable return option within a reasonable distance” (e.g., via parcel shops or brick-and-mortar drop-off points). If the customer nevertheless requests curbside pickup, the retailer may charge a corresponding fee. Only for large appliances purchased as part of a new purchase (1:1) is free pickup mandated by law.
Conclusion
With the ElektroG4, the role of retailers has fundamentally changed: It is no longer merely a point of sale, but an integral part of the national waste management infrastructure. The expansion of take-back obligations – in particular the nationwide take-back of e-cigarettes starting in July 2026 and the stricter information requirements (collection point logo) – places greater responsibility on retailers and online sellers.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
www.ecopv-eu.com/en/contact/ | 
E-Mail: info@ecopv-eu.com
Supported over 20,000 customers with EPR compliance
Rated 5.0 on Google
Contact
We look forward to your message!
