Bevollmächtigter nach § 8 ElektroG – wer ihn braucht

The Authorised Representative under § 8 ElektroG: Who Needs One

Anyone placing electrical and electronic equipment on the German market must first be registered with stiftung ear. Companies without an establishment in Germany cannot do this themselves – they need an authorised representative. This article explains who is affected, what the requirements are, and how to tell a dependable representative from a risky one.

The law – and why „establishment“ is the decisive word

„A producer within the meaning of § 3 no. 9 letters a to c who has no establishment (Niederlassung) within the scope of this Act must appoint an authorised representative.“ – § 8 ElektroG

What counts is the establishment, not the registered office. A company registered abroad that maintains an establishment in Germany registers itself and needs no authorised representative. This distinction is often blurred in practice – with the result that companies buy a service package they never needed. That is why every one of our packages states explicitly whether it is intended for customers with or without an establishment in Germany.

Who may act as authorised representative?

  • a reliable and capable legal person – a natural person, legal entity or partnership – established in Germany
  • the appointment must be made in writing and in German and be effective for at least three months
  • conclusion of the mandate is confirmed in the ear portal by electronic signature
  • anyone intending to manage more than 20 ElektroG registrations needs prior approval from stiftung ear

That last point is the single most useful question to put to any service provider. If they handle more than 20 registrations, they must be approved – ask before you sign.

What the authorised representative takes on

They assume every statutory obligation of the foreign producer, in their own name. In concrete terms:

  • registration per brand and per category of equipment in the ear portal
  • providing and maintaining the insolvency-proof guarantee for b2c equipment (§ 7 ElektroG)
  • volume notifications and the annual statistical notification
  • handling collection orders and provision orders
  • take-back and disposal of waste equipment

ElektroG versus packaging law: the difference many people miss

  • ElektroG: the authorised representative assumes every obligation – including registration.
  • VerpackDG / PPWR (since 12 August 2026): the representative takes on the EPR duties, but registration in LUCID remains the producer's personal obligation.

Assume your packaging representative handles everything and you will end up without a valid LUCID registration. The details are in our article PPWR: What has applied to sellers since 12 August 2026.

Separate rules, with their own reporting channels, apply to Batteries (BattDG) and Single-use plastics (EWKFondsG).

Checklist: how to recognise a dependable representative

  1. An establishment in Germany – verifiable, not just a mailing address.
  2. Approval by stiftung ear if more than 20 registrations are managed.
  3. A written contract in German with a clear term and termination rules.
  4. A clear answer to: who provides the insolvency-proof guarantee for b2c equipment – and what happens to it on termination?
  5. A transparent process for switching or deregistering: who files, and who pays the fees?
  6. Availability in German towards the authority – official orders come with short deadlines.

What we take on

ECOPV-EU GmbH is an authorised representative under § 8 ElektroG and, since 2024, the provider of a producer guarantee system approved by stiftung ear. You can have both from one source – or either on its own:

All prices are on our price overview. Not sure whether you need a representative at all? Write to us – the assessment is free. The registration process itself is described in WEEE registration with stiftung ear.

Sources

As at 17 September 2026. This article does not constitute legal advice.

Back to blog