WEEE registration in Germany: Stiftung EAR (2026)

Who counts as a producer under German WEEE law

Germany implements the EU WEEE Directive through the ElektroG (Elektro- und Elektronikgerätegesetz), and the register that enforces it is stiftung EAR (stiftung elektro-altgeräte register) in Fürth. The rule is blunt: whoever places electrical or electronic equipment on the German market must be registered with stiftung EAR before the first unit ships. Placing on the market means transferring equipment to third parties with the aim of selling, using or consuming it — so the obligation is triggered by your first sale to a German customer, not by any revenue or volume threshold.

The producer definition catches far more than factories. Importers into Germany, companies selling under their own brand, and — the one that surprises cross-border sellers — distance sellers all count. If you sell electronics online from the UK, the US, China, Spain or anywhere else directly to end users in Germany, ElektroG treats you as a producer with the full registration, guarantee and reporting duties, even though you have no German entity. Selling through Amazon or eBay does not move those duties to the marketplace: you remain the producer, and the marketplace is legally required to check that you registered.

A successful registration gives you a WEEE-Reg.-Nr. (format: DE followed by eight digits), published in EAR's public register of producers. Registration is granted per brand and per equipment type (Geräteart) — the brand does not need to be a registered trademark, but generic entries such as no brand are not accepted, and every brand you list under must be registered. Scope keeps widening: the ElektroG4 amendment, in force since 1 January 2026, clarifies that small connected devices such as smart plugs, IoT sensors and wearable health-tech accessories fall within scope, so borderline gadgets should be checked, not assumed exempt.

No branch in Germany? You must appoint an authorised representative

stiftung EAR is explicit about foreign companies: you cannot register yourself. A producer without a branch in Germany — and that includes companies established in other EU member states, not just non-EU sellers — must mandate an authorised representative (Bevollmaechtigter) who is located in Germany and takes over the legal producer obligations. A branch in this sense is a real permanent establishment with staff and a German tax number, so a warehouse or a virtual office does not qualify.

The mandate is formal: it must be in writing, in German, signed by both parties, and run for a minimum of three months. You may appoint only one authorised representative for all of your brands and equipment types at any given time, and switching providers means ending the existing mandate through the ear-Portal before the new one can be confirmed. The representative then registers in their own name on your behalf, and the public register shows them as acting as authorised representative for your company — which is exactly what Amazon's verification later looks up.

In practice almost every cross-border seller buys this as a service. Specialist providers (take-e-way's get-e-right, ecosistant, Bitkom Compliance Solutions, hpm and others) typically charge in the range of 300 to 800 euros per year depending on how much they include — bare representation at the low end, representation plus quantity reporting and guarantee handling at the top (checked 2026-07). stiftung EAR itself charges a one-off fee of 50.60 euros net for confirming the authorised-representative appointment.

Categories, brands and the registration steps

ElektroG sorts equipment into six categories, mirroring Annex III of the WEEE Directive: (1) heat exchangers, (2) screens and monitors with a surface over 100 square centimetres, (3) lamps, (4) large equipment with any external dimension over 50 centimetres, (5) small equipment up to 50 centimetres, and (6) small IT and telecommunications equipment up to 50 centimetres. Within these, stiftung EAR registers you per equipment type (Geraeteart), and choosing the right one matters twice: it determines your guarantee calculation, and a wrong category is one of the recurring reasons Amazon later rejects an otherwise valid WEEE number for a specific product.

The process runs through the ear-Portal: create a user account, name a legal representative and payment details, then file one registration application per brand and equipment type. For equipment that can end up in private households (B2C) you must attach proof of an insolvency-proof guarantee before registration is granted. For genuinely B2B-only equipment you instead file prima facie evidence that the equipment is not used in households, plus a take-back concept (an 18.90 euro fee applies to that review, checked 2026-07).

Timing is the trap for launch plans. stiftung EAR's own guidance says a complete and correct application normally takes three to four weeks to process; compliance providers working with foreign sellers routinely report eight to twelve weeks in practice once queues, guarantee paperwork and the authorised-representative confirmation are in the chain. There is no grace period: selling before the registration order is issued is a fineable offence, so start the process well before your intended launch — especially ahead of Q4.

The insolvency-proof guarantee for consumer equipment

If your equipment can end up with private households, German law demands an insolvency-proof guarantee each year before and during your registration — Germany is the only EU country that requires this financial security up front. The guarantee secures the financing of collection and recycling of your devices if your company disappears. The amount follows a simple formula: planned quantity placed on the market (in tonnes) multiplied by the expected return rate multiplied by the estimated disposal cost per tonne.

There are two routes. Most small and mid-size sellers join a collective guarantee system, paying an annual premium rather than parking the full guarantee amount; individual guarantees (a bank guarantee or escrow) exist for larger producers. For small to medium e-commerce sellers the guarantee typically costs around 100 to 400 euros per year, and almost all collective systems have annual minimum fees — expect a floor of roughly 120 to 150 euros even at tiny volumes (checked 2026-07). stiftung EAR reviews the guarantee annually and charges 3.80 euros net per check; letting the guarantee lapse puts the registration itself at risk.

What it actually costs (checked 2026-07)

stiftung EAR's own fees are the cheap part, and they are published: 9.50 euros net for the registration per brand and equipment type, a quarterly fee of 32.80 euros net, 3.80 euros net per guarantee check, 50.60 euros net for confirming an authorised representative — all plus VAT, and additional fees can apply depending on your constellation. The real money sits in the authorised representative, the guarantee and the physical take-back and recycling costs, which scale with the tonnage you ship. As an all-in orientation, non-EU sellers should budget roughly 800 to 1,500 euros for the complete first-year WEEE setup in Germany — official fees, representative and guarantee together — before per-kilogram recycling costs, which providers usually bill as a modest monthly admin fee plus a variable rate on actual quantities. The table below breaks this down; for the equivalent obligations and fees in other EU countries, run the WEEE producer helper linked at the end of this guide.

Amazon enforcement: how electronics listings get blocked

Marketplace verification is law in Germany, not Amazon policy. Amazon told sellers to enter their EPR registration numbers for electrical equipment in Seller Central from 1 January 2023, and since 1 July 2023 it has automatically blocked products (per ASIN) that have no valid WEEE registration number stored. eBay, Kaufland, Otto and the other German marketplaces run equivalent checks — an unregistered electronics seller simply cannot list.

The detail that catches registered sellers out is how Amazon validates. The number is checked against stiftung EAR's public register including the brand: the brand on your listing must match the brand registered with EAR essentially character for character — sellers have had numbers rejected over a spacing difference — and the product must plausibly sit in the equipment type you registered. Classic failure modes: the listing brand is a sub-brand you never registered (Apple registered, iPhone listed), the ASIN sits in a different category than your registration, or an accessory gets swept up by Amazon's classifier even though it contains no electronics.

If a listing is blocked, the fix is on the registration side first: register the exact listing brand as an additional brand (9.50 euros net per brand and equipment type), correct the equipment type if it is wrong, then submit your registration notice (Registrierungsbescheid) to Amazon Seller Support with the product evidence. And the stakes go beyond a blocked ASIN: selling unregistered is an administrative offence under section 45 ElektroG with fines of up to 100,000 euros, plus competition-law warning letters from competitors and, on marketplaces, the risk of long-term account blocks.

Beyond the WEEE number: batteries, packaging, ongoing duties

A German WEEE number does not cover everything you ship. If your devices contain or are sold with batteries, a separate battery-law (BattG) registration is required — also administered by stiftung EAR, at 16.40 euros net per brand and category (checked 2026-07) — and your parcels and product boxes trigger the separate LUCID packaging registration under VerpackG, with its own register and dual-system licence; see the German packaging (LUCID) guide in this hub. Three registers, three numbers, and Amazon can ask for all of them.

Registration is also not one-and-done. Producers must file recurring quantity reports through the ear-Portal, keep the insolvency-proof guarantee current every year, pay the quarterly register fee, carry the crossed-out wheeled bin marking and producer identification on the equipment, and quote the WEEE-Reg.-Nr. in business documents. Budget the ongoing obligations, not just the setup — an authorised representative or full-service provider will handle the filings, which is precisely what you are paying those 300 to 800 euros a year for.

Sources (checked 2026-07)

stiftung ear, stiftung-ear.de/en — applying for WEEE registration (steps, brand and equipment-type rules, insolvency-proof guarantee for B2C, prima facie evidence and take-back concept for B2B, normal processing time of 3 to 4 weeks, prohibition on selling before registration); applying as a foreign company and the authorised-representative guides (foreign companies cannot self-register; written German-language mandate, minimum three months, one representative for all brands; branch definition with German tax number); costs-and-fees guide (fee examples: registration 9.50 euros, quarterly fee 32.80 euros, guarantee check 3.80 euros, take-back concept 18.90 euros, authorised-representative confirmation 50.60 euros — net amounts plus VAT).

Global Law Experts, ElektroG Germany 2026 commentary — ElektroG4 in force 1 January 2026, small connected devices (smart plugs, IoT sensors, wearables) clarified in scope, six equipment categories, marketplace verification duty, and fines up to 100,000 euros under section 45 ElektroG.

take-e-way (product-blocking notice) and ecosistant (Amazon WEEE-number rejections) — EPR numbers required in Seller Central since 1 January 2023, automatic ASIN blocking since 1 July 2023, brand matching against the stiftung ear register including spacing-level mismatches, and the Registrierungsbescheid route to unblock. Complico Consulting (WEEE guarantee cost Germany 2026) and Compliance Gate — guarantee premiums of roughly 100 to 400 euros per year with 120 to 150 euro minimums, authorised-representative services at roughly 300 to 800 euros per year, and total first-year setup of roughly 800 to 1,500 euros for non-EU sellers.

Check your specific case

• WEEE producer EU registration helper
• EU Battery Regulation 2023/1542 compliance
• Importer and Economic-Operator Label Checker

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