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Are you facing Extended Producer Responsibility (EPR) compliance problems in Germany?

You’re in the right place!

TBA is a leading international compliance firm with a well-reputed specialism in EPR services. 

Germany WEEE

01

Regulations

Aiming to improve the management of discarded electrical and electronic devices, promoting economic recycling, enhancing resource efficiency, and ensuring proper handling and recycling of these products at the end of their lifecycle.

02

Registration

Six categories of products fall under WEEE registration:

1. Temperature exchange equipment, e.g. refrigerators

2. Screens, displays, and devices with a surface area exceeding 100 cm²: e.g., televisions

3. Lamps: e.g., LED lamps

4. Large appliances (dimensions exceeding 50 cm): e.g., washing machines

5. Small appliances (dimensions less than 50 cm): e.g., vacuum

6. Small IT and communication equipment (dimensions not exceeding 50 cm): e.g., mobile phones

03

Penalties

Failure to fulfil your registration obligation will result in online marketplaces being compelled to cease sales of any products that are classed as WEEE.

 

According to ElektroG, administrative violations such as non-registration or delayed registration, failure to declare or incorrectly declare or failure to designate an authorised representative can incur fines of up to €100,000.

Germany Packaging

01

Regulations

The Packaging Act obliges manufacturers/sellers to register if they intend to import/sell products with packaging. This includes outer packaging, final retail packaging, disposable containers used in the food industry, and transport packaging. etc. The regulations also enforce mandatory reporting of the types and weights of packaging materials sold. The Packaging Act therefore sets out mandatory requirements for the production, introduction to the German market, and management/recycling of packaging.

02

Licensed

All packaging generated by end consumers, which is typically considered waste, must be licensed. This includes transport materials such as filling/anti-shock materials and sealing materials used in transport packaging. More examples include: paper/cardboard, plastics, metals, glass, beverage carton packaging, other mixed packaging and other miscellaneous materials designed for packaging items. etc.

03

Penalties

Failure to register with ZSVR in a timely manner can result in a maximum fine of €100,000. For businesses that have deliberately avoided registering, the fine can be up to €200,000.

 

Additionally, online marketplaces may revoke selling privileges if they are unable to verify a valid registration.

Germany Battery Act

01

Compliance Obligations

Since 2009, Germany has been regulating the disposal of single-use and rechargeable batteries through the Battery Act (BattG). On 20th May 2020, a new draft of the Battery Act known as BattG2 was approved and went into effect on 1st January 2021.

Besides innovative recycling system provisions, the Federal Environment Agency (UBA) began requiring mandatory registration for battery manufacturers. This registration process is managed by Stiftung Elektro-Altgeräte Register (Stiftung EAR).

02

Types of Batteries

-Portable Batteries: These include sealed and hand-carriable batteries, button cells, battery packs, or accumulators that are not industrial or automotive batteries.

-Industrial Batteries: Any batteries or accumulators designed for industrial or professional use or for any type of electric vehicle are considered industrial batteries, e.g. electric bike batteries.

-Automotive Batteries: Any batteries or accumulators intended to power a car's starting, lighting, or ignition systems are regarded as automotive batteries.

03

Penalties

Producers who first introduce batteries, accumulators, or devices with integrated or sealed batteries into the German market must comply with the Battery Act. This means that sellers in Germany who sell batteries or products containing batteries must register with Stiftung EAR under the Battery Act.

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