EPR Compliance in Germany:
Obligations for Manufacturers & Importers Under
ElektroG4, BattDG, and VerpackDG
This guide provides a concise overview of Extended Producer Responsibility (EPR) in Germany. It is intended for all companies that place electrical appliances, batteries, or packaged goods on the German market for the first time on a commercial basis.
Learn step by step what registration, reporting, and disposal obligations you face under the ElektroG4, BattDG, and VerpackDG. We clarify the legal roles of manufacturers and importers, outline the necessary compliance steps with the EAR Foundation and the LUCID Register, and help you reliably avoid hefty fines or sales bans.
ear Foundation: WEEE Registration and the ElektroG4
The Foundation for the Register of Waste Electrical Equipment (Stiftung ear) oversees the implementation of the ElektroG4 (Electrical and Electronic Equipment Act) and the BattDG (Battery Act). The goal is to ensure a competitive market and the environmentally sound disposal of waste equipment.
Key obligations for manufacturers
- Registration Requirement: Every manufacturer and every product must be registered on the ear portal. Electrical appliances may not be imported or sold in Germany without a valid WEEE registration number.
- Insolvency-Proof Guarantee: A guarantee, subject to annual review, must be provided to finance future disposal.
- Volume Reporting: Manufacturers must report monthly and annually the quantities placed on the market by category and brand.
- Collection Coordination: The ear Foundation coordinates the provision of collection containers and the pickup of waste equipment by public waste management authorities.
Important: Foreign manufacturers without a German branch must appoint an official authorized representative in accordance with Section 8 of the ElektroG to fulfill their obligations.
ZSVR & LUCID: The Packaging Act (VerpackDG)
The most important requirements:
LUCID Registration: Every company (first-time distributor) requires a LUCID number. Since July 2022, the registration requirement has also applied to transport, reusable, and commercial packaging.
System Participation (Licensing): To finance the waste management infrastructure, manufacturers must enter into a contract with a dual system and pay licensing fees.
Data reporting: The quantities of packaging used must be reported identically to both the dual system and the LUCID portal.
Recyclability: The law requires continuous optimization of packaging with regard to material recovery.
Who is legally considered the manufacturer?
Under EU directives and national laws (ElektroG4, BattDG, VerpackDG), the term “manufacturer” is broadly defined. The decisive factor is the role of first-time distributor on the German market.
The following are considered manufacturers under the law:
- Foreign companies that sell goods directly to German end customers (B2C).
- Importers and resellers who import products from abroad or distribute them in Germany under their own name.
- Online retailers who make goods available on the German market for the first time.
There are five key pillars of compliance for electrical and electronic equipment:
- Registration: Mandatory registration by brand and category on the ear portal to obtain the WEEE registration number.
- Insolvency-proof guarantee: Financial security for the disposal of B2C equipment.
- Volume reporting: Monthly reporting of the weights of equipment placed on the market.
- Annual statistical reporting: Annual documentation of material flows and waste equipment.
- Pickup coordination: Ensuring logistics for the provision of collection containers by the ear Foundation.
- B2C classification (dual-use): Products that can also be used in private households are classified as B2C devices under regulations. This means that stricter take-back and disposal obligations apply.
- Labeling: The WEEE symbol (crossed-out wheelie bin) must be affixed to the product in accordance with Section 9 of the ElektroG.
The following obligations apply to the distribution of batteries or devices containing batteries (rechargeable batteries):
- Registration: Registration with the ear Foundation by chemical system and type.
- Take-back system: Obligation to join an approved take-back system (OfH) to ensure nationwide disposal.
- Quantity reporting: Regular (monthly to annual) reporting of the quantities of batteries placed on the market.
- Obligation to provide take-back and collection points: Retailers and distributors are required to set up collection points for used batteries at the point of sale (in the store or in the immediate vicinity). Customers must be able to return used batteries there free of charge.
- Manufacturers and first-time distributors (e.g., importers), on the other hand, bear full financial responsibility for the product: They are legally required to join an approved take-back system (OfH).
All packaging that reaches the end consumer must be licensed:
- System participation: Entering into a contract with a dual system (licensing).
- LUCID reporting: Verification of volume reports in the Central Packaging Register (ZSVR).
- Recycling: Compliance with minimum standards for the recyclability of the materials used.
- New: The PPWR (EU Regulation) and the VerpackDG (Packaging Implementation Act) will be implemented together starting in August 2026.
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