info@ecopv-eu.com
+49 6196 5835357
info@ecopv-eu.com
+49 6196 5835357
All questions regarding PV registration, EAR categories, the EAR Foundation, the ElektroG, and photovoltaic components. This detailed guide answers your questions about the legally compliant implementation of the ElektroG for solar modules in Germany. ECOPV-EU, a specialized full-service EPR provider, is here to support you in ensuring a smooth process.
FAQ: Frequently Asked Questions About Photovoltaics & PV Modules
Basics & Legal Framework
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 & Jurisdiction
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.
B2C vs. B2B & Commercial Systems
Yes. Modules for commercial rooftop systems and ground-mounted installations are also subject to the WEEE registration requirement. However, modules that can be proven to be exclusively B2B are exempt from the requirement for an insolvency-proof guarantee and from participation in the municipal collection coordination program.
To be classified as a B2B module, the EAR Foundation requires a rigorous verification process. The manufacturer must prove that the modules are used exclusively for commercial purposes. Since many standard modules are installed identically on both residential rooftops and in solar parks, the EAR classifies them by default as B2C (“dual-use”). Only a clear, distribution-channel-based distinction protects against costly retroactive claims.
In the case of genuine B2B sales to commercial project developers, the insolvency-proof guarantee does not apply. Instead, the manufacturer must organize and finance the disposal of end-of-life modules entirely on its own. The WEEE registration requirement itself remains unchanged.
The manufacturer must demonstrate on the EAR portal that the goods cannot end up in private households. Disposal may not be handled through municipal recycling centers but requires the manufacturer’s own take-back logistics. In addition, the B2B quantities placed on the market and taken back must be reported annually to the EAR in a statistical report. If the same modules are sold to private end users at the same time, the quantities must be strictly separated into B2C and B2B in the system.
Warranty & Costs
Yes, for B2C modules. Since solar modules are typically used on private homes (e.g., as rooftop systems or balcony power plants), the EAR Foundation classifies them by default as B2C devices (“dual-use”). This requires manufacturers to provide annual proof of an insolvency-proof warranty.
Because photovoltaic modules have an extremely long service life of 25 to 30 years, the warranty provides long-term coverage for disposal costs in the event of a future manufacturer insolvency. Without this valid proof, the EAR Foundation blocks the WEEE registration number, resulting in an immediate sales ban. For purely B2B large-scale systems, the guarantee requirement does not apply, provided the manufacturer successfully completes the EAR’s formal verification process. The majority of suppliers use collective guarantee systems from EPR service providers such as ECOPV-EU to prevent their own liquidity from being tied up by bank guarantees.
The warranty costs are not set at a flat rate. They are calculated on a case-by-case basis based on the planned sales volume in metric tons and the category-specific parameters for disposal costs specified by the EAR Foundation.
Since solar modules have a very high unit weight compared to other electronic devices, the calculated guarantee amounts can quickly rise as sales volumes increase. Individual bank guarantees or escrow accounts tie up significant financial resources. Joining a collective guarantee system recognized by the EAR is usually the most liquidity-friendly option for growing solar companies, as it requires only an annual fee rather than full capital collateral. If actual import volumes exceed the forecast during the year, the guarantee must be actively increased through the EAR portal.
Marking
Yes. Every PV module must be permanently and weather-resistant marked with the crossed-out trash can symbol, the manufacturing period (bars below the trash can), and the precisely registered brand.
The marking is usually applied via a durable nameplate on the back or an engraving in the frame. It ensures that the module can be traced back to a responsible market participant even after decades of outdoor use. The WEEE registration number itself does not belong on the product but must be provided in business transactions – particularly on invoices, delivery notes, and in online legal notices – as proof of compliance.
Take-Back, Recycling & End-of-Life
Old modules are mechanically, thermally, and chemically dismantled in specialized facilities. The law mandates a recovery rate of 85 percent and a pure recycling rate of 80 percent for this class of equipment.
First, the aluminum frames, cables, and electronic junction boxes are removed. The remaining glass-cell composite is shredded or thermally processed to burn off or peel away the protective plastic film (EVA). High-quality silicon, silver, and copper are then chemically extracted from the exposed solar cells and returned to the raw materials market. Modern recycling facilities significantly exceed the statutory minimum recycling rates and return up to 95 percent of the module’s weight – primarily the glass and metals – back into the economic cycle.
End-of-life PV modules must be collected separately and must not, under any circumstances, be disposed of with household waste or construction debris. End users can drop off typical household quantities (up to 20–50 modules) free of charge at municipal recycling centers.
In the case of repowering or system replacement, the installation companies carrying out the work usually organize the dismantling and removal. They either take the old modules to municipal collection points or directly to the manufacturers’ take-back systems. The costs for the actual recycling are covered by registered manufacturers through their EAR fees.
Yes. The statutory take-back obligations for retailers apply across all categories, including photovoltaic components, provided that retailers exceed the 400-square-meter threshold for electrical appliances.
However, since solar modules are rarely sold through traditional retail channels but rather through B2B specialty wholesalers and solar installers, in practice, disposal is usually handled through installation companies or municipal recycling centers. Nevertheless, larger photovoltaic retailers and online distributors must offer free return options (1:1 take-back upon the purchase of new large appliances). Under the ElektroG4 amendment, PV retailers have also been required since July 2026 to clearly display this service offering using the nationwide collection point logo in-store or during the online ordering process.
The mere resale of used, intact solar modules within Germany does not trigger a new WEEE registration requirement, as long as the original manufacturer’s brand remains unchanged and the device has already been registered in Germany once.
However, if the product undergoes fundamental technical modifications, is completely overhauled, or is offered under a new private label as part of a “second life” application, the original manufacturer’s liability expires. The refurbishing company is then legally considered a new manufacturer under the ElektroG. Additionally, a separate registration and warranty obligation arises immediately when used modules are imported into Germany from abroad, as this is considered the first time the product is placed on the German market.
Special Cases: Storage Systems & Balcony Power Plants
Battery storage systems are subject to two sets of regulations simultaneously: the ElektroG for the housing and control electronics, and the Battery Implementation Act (BattDG) and the EU Battery Regulation for the battery cells. Suppliers of complete PV kits must therefore complete separate registrations on the EAR portal.
Since PV storage systems are typically based on lithium-ion technology, strict safety and take-back requirements apply due to fire risks. Manufacturers must register the product in both the WEEE Register and the Battery Register maintained by the EAR Foundation. In addition, a contractual affiliation with an approved take-back system for industrial batteries is mandatory. Anyone who overlooks battery compliance and applies only for the WEEE number for modules risks sales bans and fines from the Federal Environment Agency. Full-service providers such as ECOPV-EU consolidate these parallel EPR obligations for solar providers.
The components of balcony power plants are fully subject to the ElektroG. Since plug-and-play mini-solar systems are specifically marketed to private individuals, the EAR Foundation classifies the modules and inverters as B2C devices subject to a full, insolvency-proof warranty obligation.
The e-commerce market for balcony power plants is strictly monitored. Online marketplaces automatically cross-check the WEEE numbers of new sellers against the EAR registry before they go live. If the brand or device category does not match exactly, the listing is immediately blocked. In addition, as of July 1, 2026, retailers must display the nationwide take-back logo during the ordering process and actively inform consumers about the free return of used modules and any storage batteries they may contain.
Service Provider/Support
As a specialized full-service EPR provider based in Eschborn, ECOPV-EU handles all administrative processes for the solar industry. The service bundles WEEE registration for modules and inverters, as well as BattDG reporting for battery storage systems, under one roof.
We guide companies through the EAR portal in full compliance with the law and ensure the correct categorization of solar components. To preserve our clients’ liquidity, we provide a government-recognized, collective guarantee system that eliminates the need for expensive bank guarantees. We fully handle the ongoing monthly reporting requirements. For international market participants without a German branch, we also act as a statutory, domestic authorized representative to guarantee fast and legally compliant market access in Germany.
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