Frequently Asked Questions
These questions follow the path our customers actually take — from “Does this even apply to me?” through to what changed in 2026.
1. Do I even need this?
Which products fall under Extended Producer Responsibility (EPR)?
Extended Producer Responsibility applies to electrical and electronic equipment (WEEE), batteries, packaging and single-use plastic products placed on the German market.
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.
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.
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.
Is there a minimum quantity below which I need do nothing?
Not for the single-use plastics levy: it 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.
2. What exactly do I need — and how does it fit together?
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.
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.
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.
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).
What does ECOPV-EU do for you?
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.
3. Cost: what is included — and what is not?
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
- 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.
4. I am already registered — what then?
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 WEEE and batteries and by whether you have a branch in Germany. You do not need a new service contract for it.
5. What changed in 2026?
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.
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.
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.
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.
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.