Frequently Asked Questions on EPR Compliance in Germany
This FAQ answers questions about Extended Producer Responsibility (EPR) in Germany – for electrical equipment (ElektroG/WEEE), batteries (BattDG), packaging (VerpackDG/PPWR) and single-use plastics (EWKFondsG). Written for manufacturers, importers and online retailers selling into Germany – with or without a branch (Niederlassung) in Germany.
Scope: Germany. EPR is regulated nationally: a German registration is not valid in other EU countries. For our services in other European countries, see the section Other European countries. Last updated: 27 September 2026.
Contents
- Deadlines and key dates in Germany at a glance
- Basics: who is affected by producer responsibility in Germany?
- Electrical equipment: ElektroG and WEEE registration
- Batteries: BattDG and registration with stiftung ear
- Packaging: VerpackDG, PPWR and the LUCID packaging register
- Single-use plastics: EWKFondsG and DIVID
- Cost, process and scope of services
- Existing registrations: switching, adding, deregistering
- Other EU countries
- About ECOPV-EU
Deadlines and key dates in Germany at a glance
| Area | Obligation | When |
|---|---|---|
| ElektroG (WEEE) | Registration with stiftung ear; insolvency-proof guarantee under § 7 ElektroG for B2C equipment | before first placing on the market |
| ElektroG (WEEE) | Volume report (Mengenmitteilung) in the ear portal | monthly |
| ElektroG (WEEE) | Annual statistics report | annually |
| ElektroG (WEEE) | Take-back of single-use e-cigarettes at all points of sale | since 1 July 2026 |
| BattDG | Registration with stiftung ear and participation in a producer responsibility organisation (OfH) | before first placing on the market |
| BattDG | Every registration in the battery register must be assigned to an approved OfH; without the assignment the registration counts as incomplete | since 15 January 2026 |
| BattDG | Appointment of an authorised representative in Germany for manufacturers without a German branch | since 18 August 2025 |
| BattDG | Replaced the old Battery Act (BattG) | in force since 7 October 2025 |
| VerpackDG / PPWR | Replaced the Packaging Act (VerpackG) | in force since 12 August 2026 |
| VerpackDG | Registration in the LUCID packaging register, system participation contract, data report | before first placing on the market, then ongoing |
| VerpackDG | Declaration of completeness under § 10 VerpackDG | annually by 15 May for the previous year |
| PPWR | Empty-space limits, design for recycling, minimum recycled content | from 2030 |
| EWKFondsG | Reporting previous-year volumes via the DIVID platform | annually by 15 May for the previous year |
Basics: who is affected by producer responsibility in Germany?
Which products fall under Extended Producer Responsibility (EPR) in Germany?
Extended Producer Responsibility applies to electrical and electronic equipment (WEEE), batteries, packaging and single-use plastic products placed on the German market. Each of these four areas has its own act, its own register and its own reporting duty – one registration does not cover the others.
Is there a minimum quantity below which I need do nothing?
No. The single-use plastics levy applies from the first gram. That is separate from the verification threshold – from 100 kg per product category per year, reported data must be confirmed by an independent verifier. For WEEE, batteries and packaging too, small volumes do not automatically create an exemption; at most they affect the level of the fees.
What is the difference between registration, system participation and an authorised representative?
These are three different things, and they are often confused:
- Registration – the entry in the official register: with stiftung ear for electrical equipment and batteries, in the LUCID packaging register for packaging. Registration in LUCID itself is free of charge.
- System participation – only for packaging subject to system participation. Registration alone is not enough here: you also need a system participation contract with a dual system and must report your packaging volumes regularly – including to the LUCID packaging register (data report).
- Authorised representative – a person or company established in Germany, appointed by a manufacturer without a branch (Niederlassung) in Germany to fulfil that manufacturer’s obligations in its own name. Only one authorised representative may be appointed per manufacturer, covering all brands and device categories. The appointment must be in writing, in German, and signed by both parties.
So an authorised representative does not replace registration – they are the party who carries it out and holds it for you.
Do I need an authorised representative if I have a branch in Germany?
No. § 8 ElektroG requires an authorised representative only from manufacturers without a branch (Niederlassung) within the scope of the act. What matters is the branch, not the registered seat: a company with its seat abroad that maintains a branch in Germany registers itself. There are separate packages for both cases – with a branch and without a branch, with an authorised representative.
What do foreign companies need in order to be fully compliant in Germany?
In each regulatory area you need two things, not one:
- ElektroG / WEEE: a German authorised representative – ECOPV-EU GmbH – and an insolvency-proof guarantee under § 7 ElektroG.
- BattDG / batteries: registration with stiftung ear and participation in an approved producer responsibility organisation (OfH).
- VerpackDG / packaging: registration in the LUCID packaging register and a system participation contract with a dual system.
What happens if I sell into Germany without registering?
A sales ban applies – immediately, not after a grace period. On top of that come fines, warning letters from competitors and the suspension of your listings on marketplaces, because their operators are required to check registration numbers. For packaging and single-use plastics, the unreported volumes of previous years must also be filed retroactively.
Is my German registration also valid in other EU countries?
No. EPR obligations are regulated nationally: every EU country has its own registers, deadlines and rules on authorised representatives. If you sell into several countries, you need a separate registration in each target market. See the section Other EU countries.
Electrical equipment: ElektroG and WEEE registration in Germany
Who counts as a “manufacturer” under the ElektroG?
Not only those who physically make the products. Anyone who imports electrical equipment into Germany, or who ships it directly to end customers in Germany as a foreign retailer, counts as a manufacturer. You will find the matching packages under Electrical equipment (ElektroG / WEEE).
Do I need a WEEE number to sell on Amazon, eBay or Kaufland?
Yes. Under the ElektroG, marketplace operators must verify that their sellers are registered for the device categories they offer. Without a valid WEEE registration number, the listing is blocked or never goes live in the first place. The number belongs to the manufacturer and covers exactly the brands and device categories entered in your registration – if a brand is added, it must be reported.
What is the insolvency-proof guarantee under § 7 ElektroG – and who needs it?
It is mandatory for all equipment that can be used in private households (B2C) and a precondition for registration. The guarantee ensures that the disposal of your waste equipment remains financed even if your company becomes insolvent. It is provided per device category and renewed for each year. Pure B2B equipment does not require a guarantee. Prices per device category are listed under Guarantee for manufacturers.
How long does WEEE registration in Germany take?
We submit your application within 3 working days once your documents are complete. How long stiftung ear then takes to grant it is up to the authority: typically 6 to 8 weeks per device category. That is a value based on experience, not a guaranteed outcome. Plan your sales launch accordingly – you may not place products on the market before the registration is granted.
What changed with ElektroG4?
The fourth amendment closed gaps in online retail: operators of e-commerce marketplaces must verify that their sellers hold a valid WEEE number. Since 1 July 2026, all points of sale – including kiosks and petrol stations – must also take back single-use e-cigarettes.
Batteries: BattDG and registration with stiftung ear
Who is affected by the BattDG?
Not only battery factories. It covers manufacturers producing batteries in Germany; importers bringing batteries into Germany from outside the EU – including batteries built into devices such as laptops, e-bikes or power banks; and foreign retailers shipping directly to German customers.
Which batteries are regulated?
Five battery categories: portable batteries (household batteries, button cells); LV batteries (batteries for light means of transport) such as e-bikes and e-scooters; starter batteries; industrial batteries including stationary storage; and electric vehicle batteries. Each category is registered separately; the packages are listed under Batteries (BattDG).
Which steps are mandatory for batteries?
Two, and both are required. First, registration: every manufacturer needs a valid registration number (Batt-Reg. No.) with stiftung ear – without it, an immediate sales ban applies. Second, participation in an approved producer responsibility organisation (OfH).
Since when must every battery registration be assigned to an OfH?
Since 15 January 2026. Every registration in the stiftung ear battery register must be assigned to an approved producer responsibility organisation; without that assignment the registration counts as incomplete. You provide proof via a PIN issued by the OfH, which you store in your account in the ear portal. If your registration already exists and only the OfH is missing, book OfH participation for portable batteries on its own.
How long does battery registration take?
Registration under the BattDG is considerably faster than WEEE registration. We submit within 3 working days once your documents are complete; stiftung ear typically grants it within a few working days. This too is a value based on experience, not a guaranteed outcome. OfH participation must also be in place before you start selling.
What changed with the BattDG?
The Batterierecht-Durchführungsgesetz (BattDG) entered into force on 7 October 2025 and fully replaced the old Batteriegesetz (BattG). It implements EU Battery Regulation (EU) 2023/1542 at national level. Since 18 August 2025, manufacturers without a German branch must also appoint an authorised representative in Germany.
Packaging: VerpackDG, PPWR and the LUCID packaging register
Has the Packaging Act (VerpackG) been repealed?
Yes. The Verpackungsgesetz (VerpackG) was replaced on 12 August 2026 by the Verpackungsrecht-Durchführungsgesetz (VerpackDG), the German act accompanying the directly applicable EU Packaging and Packaging Waste Regulation (PPWR).
What is the PPWR, and what changed on 12 August 2026?
The PPWR (Packaging and Packaging Waste Regulation) is an EU regulation that has applied directly in all member states since 12 August 2026. It replaces the previously divergent national packaging rules with uniform EU requirements. The VerpackDG governs national implementation – competences, registers and procedures.
What do I need as a foreign online retailer for packaging in Germany?
Three things: an authorised representative under § 5 VerpackDG, registration in the LUCID packaging register and a system participation contract. After that you report your volumes on an ongoing basis to LUCID and to the dual system. We handle all of it – see packaging services for Germany. The dual system’s fees depend on material and volume and are invoiced separately.
What is the declaration of completeness (VE), and from which volume do I need one?
The VE is a confirmation of your previous-year volumes, to be filed annually by 15 May – required as soon as you reach one of the statutory volume thresholds: 80 t of glass, 50 t of paper, paperboard and cardboard, or 30 t of lightweight packaging. Reaching any one of these thresholds is enough. Only a registered verifier may file the VE – see Declaration of completeness under § 10 VerpackDG.
Is there now a ban on empty space in shipping boxes?
Not yet. The empty-space limits for shipping packaging take effect from 2030, together with design-for-recycling requirements and mandatory minimum recycled content in plastic packaging.
Can I use up packaging I already have?
Yes, within the statutory transition rules. Packaging stock demonstrably produced and placed on the market before 12 August 2026 has legacy protection and may be used up. Exceptions apply – we check case by case whether your stock falls under them.
Single-use plastics: EWKFondsG and DIVID
Who counts as a “manufacturer” under the EWKFondsG?
What matters is not who produces the item, but who first places it on the German market. This covers domestic manufacturers and bottlers, importers, and foreign online retailers shipping directly into Germany. Without a branch in Germany you need an authorised representative for single-use plastics.
Which products are subject to the single-use plastics levy?
Among others: to-go food containers, bags and film packaging, drink cups and containers up to 3 litres, lightweight plastic carrier bags, wet wipes, balloons and tobacco filters, as well as certain fireworks containing plastic.
When is the EWKFondsG report due?
By 15 May each year, for the preceding calendar year, via the DIVID platform. You report the exact weight in kilograms of the products placed on the market. After the May submission, the Federal Environment Agency sets your individual levy.
Cost, process and scope of services
What does EPR compliance in Germany cost?
All prices are published in the shop – you do not have to request a quote. An overview of all service packages by regulatory area is on the Prices page. All amounts are net prices plus VAT and cover our service; fees charged by authorities and systems come on top (see the next question).
What is not included in our service packages?
Our prices cover our service. Not included are:
- stiftung ear fees
- system participation fees for packaging (dual system)
- the single-use plastics levy payable via DIVID
- the cost of an independent verifier where verification is required by law
- costs for collection and disposal of waste equipment
- statutory VAT
These amounts are charged directly by the authorities or the systems and depend on the volumes you report. We state them openly rather than folding them into a flat package price.
How does working with us work?
In four steps: you book the right package in the shop; we request the documents needed; we file with the competent body within 3 working days once the documents are complete; once granted, we take over the ongoing reporting duties for the service period booked. Not sure what you need? The compliance check clarifies that up front.
Existing registrations: switching, adding, deregistering
I already have a WEEE number. Do I have to start over if I appoint an authorised representative?
Not necessarily – but the change has to be handled cleanly. Only one authorised representative may be appointed per manufacturer, covering all brands and device categories. stiftung ear first confirms the appointment; only then is the registration application processed. Once granted, the authorised representative appears in the register of registered manufacturers, noted as acting in that capacity. If an existing appointment ends, stiftung ear revokes the registrations held through it – so a switch should never happen without a proper handover. Tell us in advance what already exists and we will plan the transition.
How do I report additional brands, device categories or battery categories?
Brands, device categories and battery categories form part of your registration – if one is added, it must be reported. We have separate items for this, split by electrical equipment and batteries and by whether you have a branch in Germany. You do not need a new service contract for it.
How do I deregister if I no longer sell into Germany?
Deregistration is a separate procedure – it does not happen automatically when you stop selling. Two things need to be kept apart: notifying the competent authority that you are permanently giving up placing products on the market (§ 6 (1) sentence 4 ElektroG), and the actual deregistration of the registration, for which fees apply. We handle both – deregistration of electrical equipment and deregistration of batteries, in each case per registration.
Other European countries
Which countries besides Germany do you cover?
Alongside Germany we handle EPR registration in 23 further European countries – including France, Italy, Spain, the Netherlands, Poland and Austria, plus the non-EU countries Norway and Switzerland – for electrical equipment, batteries and packaging, and in some countries as a combined package. All countries with prices are listed in the price overview.
Do I need a separate registration per waste stream in each country?
Yes. A country with three waste streams means three registrations, not one. Electrical equipment, batteries and packaging are registered separately and reported separately in every EU country. In France, for example, you receive a separate Identifiant Unique (IDU) per waste stream. Ship one electrical device in a cardboard box and you are subject to registration in two streams – even though it is a single product. One exception concerns our packages, not the registers: in Poland we offer combined packages only.
Do I need a separate authorised representative in every country?
As a rule, yes. Whether you must appoint an authorised representative follows the national law of the target country and depends on whether you are established there. Anyone selling into several EU countries without being established there therefore normally needs a separate appointment per country – a German authorised representative does not cover France or Poland. You do not have to arrange this country by country yourself: we provide the appointment in the target country, see the question after next.
In which countries do I not need an authorised representative?
In the Netherlands – the only country in this overview where companies based in the EU need no authorised representative. Whether companies outside the EU (for example Chinese companies) must appoint one there is still under discussion. You register directly there, which makes the packages noticeably cheaper than in the other countries. In Sweden, producers selling directly to end users by distance contract and established in another member state or a third country must appoint an authorised representative – regardless of whether the end users are private households. In all other countries we cover, manufacturers without an establishment in the target country need an authorised representative.
Who is my contracting party, and who represents me in the target country?
The contracting party is ECOPV-EU GmbH, based in Eschborn, throughout – even when several countries are involved. The role of authorised representative in the target country is taken by one of our group companies or by a local partner company: ECOPV SASU in Strasbourg for France, ECOPV-ITALY S.R.L. in Milan for Italy, ECOPV srl in Uccle near Brussels for Belgium, Ecopv-sweden AB in Åkersberga near Stockholm for Sweden, EPR Experts Ltd in Dublin for Ireland, and ECOPV-EU GmbH based in Salzburg for Austria. In Spain and Poland we work with local partner companies. Each country page states which company acts for you.
How long does registration in another European country take?
Between two weeks and four months – depending on the country and the EPR obligation. The Netherlands is fastest, at two to four weeks for electrical equipment and batteries. Austria takes longest, at three to four months, because applications there are submitted in quarterly batches. Packaging takes longer than electrical equipment almost everywhere: ten to sixteen weeks in Italy, at least three months in Spain. Why the range is so wide: two bodies are involved, not one. Besides the authority that reviews at the end, most EPR obligations also involve a producer responsibility organisation (PRO) with its own document requirements and its own processing speed. For packaging in Italy, for example, the system admits you first; only then does the authority carry out its review. If either body is slow, everything downstream shifts. The range per EPR obligation is stated on every country page and on every product page. All of these figures are values based on experience, not guaranteed outcomes – the registers and systems decide how long processing takes, not we. What is guaranteed is submission within 3 working days once your documents are complete.
Can I book several countries in a single order?
Yes. Put the packages for the countries you need into the cart together – you order once and receive one invoice. Behind that, each country remains a separate matter with its own register, its own reporting frequency and its own processing time. There is no bundled price across several countries; it only gets cheaper where a country itself allows a combined package covering several waste streams. If you are unsure which countries you need, the Amazon mandatory countries overview helps, or the compliance check beforehand.
I sell on Amazon in several countries – where do I need to be registered?
In every country where you sell or store. Since 12 August 2026, Amazon has been verifying packaging registration in every EU country where you sell or store – no longer only in Germany and France. For batteries, country-specific registration has been checked since 18 August 2025. Storing counts as selling: if your goods sit in a marketplace warehouse abroad, the registration obligation applies there – even without a single sale in that country. Without a valid registration number, listings are blocked, in several countries with no transition period and no warning. All affected countries are collected under Amazon mandatory countries.
Is the price per year, and what happens the following year?
The country packages apply to the service period you select in the product – currently 2026. The registration itself is not used up by that, but the ongoing reporting and notification duties arise again every year, as does membership in the respective systems. The package is therefore booked again for the following period. If you stop selling in a country, the registration has to be deregistered – it does not end automatically just because you stop selling.
How do I pay, and are the prices net?
All prices in the shop are net prices plus statutory VAT; payment is made in advance by PayPal or bank transfer. In every country, the fees charged by the registers and the recycling and system charges are not included unless the package explicitly says so – they depend on the volumes you report. What is already included per country is stated on the relevant product page; several country packages include a recycling base amount, for example. The details of how the contract is formed are set out in our terms and conditions.
About ECOPV-EU
What exactly does ECOPV-EU do?
We take on producer obligations for companies selling into Germany and the EU: registration, reporting and ongoing compliance under the ElektroG, BattDG, VerpackDG and EWKFondsG – including acting as your authorised representative if required. ECOPV-EU GmbH is a German company based in Eschborn near Frankfurt am Main; the legal details are in the legal notice.
My question is not answered here – what now?
Write to us via the Contact page or call us: +49 6196 5835357. For a structured first assessment there is the Compliance check & basic workshop.