WEEE Compliance in Germany
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Bitkom Compliance Solutions
Bitkom Compliance Solutions is your trusted supporter for legal requirements under the WEEE Directive and the Battery Act (BattG) in Germany.
Frequently Asked Questions
A manufacturer under the ElektroG is:
A distributor who offers electrical appliances from unregistered manufacturers for sale without proper registration has the same responsibility as a manufacturer.
Special manufacturer constellations:
OEM
A producer who manufactures its products without affixing its own brand (e.g. original equipment manufacturer – OEM) is not considered a manufacturer under the ElektroG. Instead, the customer of the producer who sells the product under its own brand is the manufacturer.
Advertising material supplier
A supplier of advertising material can be registered as a manufacturer if it manufactures the electrical equipment itself and affixes its own brand to it. However, if the supplier manufactures electrical equipment exclusively under the customer’s brand, the customer is the manufacturer.
Assembler
Companies that assemble electrical appliances from different parts (assemblers) may also be considered manufacturers. If the assembler uses parts for which the manufacturer is registered in Germany, the parts must remain labelled accordingly.
All electrical appliances are covered by the ElektroG. This does not apply if an appliance is explicitly excluded.
Electrical appliances:
The ElektroG does not only cover ‘classic’ electrical appliances. Products with electrical or electronic components such as furniture, clothing or lifestyle products may also fall within the scope of the law.
Finished electrical appliance or just a component?
Electrical appliances are always end devices, i.e. ‘finished’ products.
An end device can be recognised by the fact that it:
In contrast, mere components are not covered by the law.
A kit is considered an electrical appliance if it can be assembled into an electrical appliance by the end user.
The European WEEE Registers Network (EWRN) – the association of national registers for electrical and electronic equipment in EU member states – has produced a guide to help distinguish between components and electrical appliances.
Registration is carried out exclusively online on the ear portal. Once the registration application has been reviewed by stiftung ear, you will receive either a message or the registration notice with the registration number at the email address of the main contact person provided. Please note: Registration can only be granted if the registration application contains plausible information about the brand, a device type has been selected and a complete application has been submitted.
