Germany’s EPR Regulations: What Businesses Need to Know About VerpackG and WEEE Compliance

Germany’s EPR Regulations: What Businesses Need to Know About VerpackG and WEEE Compliance

As global demand for sustainable practices grows, more countries are introducing Extended Producer Responsibility (EPR) programs to hold producers accountable for the environmental impact of their products. EPR ensures that producers—not consumers or governments—bear the responsibility for their products throughout the entire lifecycle, including post-consumer waste management.

Germany is among the leading countries in Europe implementing and enforcing strict EPR regulations. This article outlines the current German EPR rules for packaging and electrical equipment, including compliance steps and penalties for non-compliance.

Overview of Germany’s EPR Framework

Germany operates several EPR schemes, each targeting different types of waste. The most notable include:

· VerpackG (Packaging Act)

· ElektroG (Electrical and Electronic Equipment Act)

· Battery regulations under the Battery Act

Each of these requires producers and sellers to register, report, and contribute to recycling systems based on the type and volume of goods they place on the market.

VerpackG – Packaging Compliance (Enforced from July 1, 2022)

The German Packaging Act (VerpackG) officially became mandatory on July 1, 2022, although voluntary compliance was previously encouraged during a transitional period.

This law applies to all businesses placing packaging on the German market, including product packaging, shipping boxes, fillers, and any materials used for protection or delivery.

Key Requirements:

1. Register with LUCID Packaging RegisterProducers must sign up with LUCID, managed by Zentrale Stelle Verpackungsregister (ZSVR), Germany’s central authority for packaging compliance. Registration provides an official EPR number and license.

2. Work with a Dual SystemCompanies must also partner with a Dual System Provider, which manages the collection and recycling of packaging waste.

3. Marketplace VerificationPlatforms like Amazon are legally obligated to verify a seller’s VerpackG registration. Listings from unregistered businesses will be removed.

4. Annual Reporting & FeesBusinesses are required to report annual sales volumes and pay corresponding recycling fees, based on the amount and type of packaging placed on the market.

ElektroG – WEEE Regulations for Electronics (Enforced from July 1, 2023)

Building on the success of VerpackG, Germany began enforcing ElektroG (the German Electrical and Electronic Equipment Act) as of July 1, 2023. This act regulates the collection, disposal, and recycling of electrical and electronic equipment under the EU WEEE Directive.

Registration Requirements:

Businesses must register with Stiftung EAR (Elektro-Altgeräte Register) before selling electronics in Germany. This applies to manufacturers, importers, and sellers offering electronic devices to German customers.

WEEE Product Categories:

Electronics are grouped into six categories:

1. Temperature exchange equipment

2. Screens and monitors (surface > 100cm²)

3. Lamps

4. Large equipment (over 40 cm)

5. Small equipment (under 50 cm)

6. Small IT and telecommunication devices (under 50 cm)

Note: Individual components, such as bulbs, are generally not subject to registration unless they are sold as standalone products.

Monthly Reporting & Marketplace Obligations:

· Registered companies must submit monthly sales reports to Stiftung EAR

· Online marketplaces like Amazon will delist unregistered listings without valid WEEE numbers

· Contribution fees may apply based on reported volumes

Non-Compliance Penalties

Failure to comply with either VerpackG or ElektroG can result in significant penalties, including:

· Fines up to €100,000

· Legal action for unfair competition

· Liability for damages if competitors claim your non-compliance gave you an advantage

False reporting or under-declaring volumes can also trigger enforcement actions and financial penalties.

Batteries Are Regulated Separately

Batteries do not fall under WEEE regulations. Instead, they are managed under Germany’s Battery Act, with a similar registration process through Stiftung EAR. Battery types include:

· Portable batteries

· Industrial batteries

· Automotive batteries

All producers must register accordingly and report their battery sales volumes on a scheduled basis.

Stay EPR-Compliant with TBA Ecofuture

Navigating Germany’s EPR laws requires precision, planning, and expert knowledge. At TBA Ecofuture, we help international sellers, manufacturers, and e-commerce merchants stay compliant with:

· LUCID packaging registration

· WEEE registration with Stiftung EAR

· Ongoing reporting and fee management

· EPR marketplace support for platforms like Amazon and eBay

Our team simplifies the process and ensures you remain compliant under Germany’s evolving regulatory framework.

---

Additional Requirements for Foreign Sellers

Germany’s approach to Extended Producer Responsibility (EPR) continues to evolve. One key change was the introduction of the ElektroG2 amendment on August 10, 2015, which expanded the scope of the existing WEEE legislation.

Under ElektroG2, the definition of a “producer” was broadened to include many more types of sellers, including overseas companies. Businesses without a legal entity in Germany are now required to appoint an Authorised Representative (AR) to handle their WEEE obligations.

This means that if you’re a foreign seller offering electronic or electrical goods to customers in Germany, you cannot register directly. Instead, your appointed AR will manage the entire WEEE compliance process on your behalf, from initial registration to monthly reporting.

Companies that were already registered before the rule change had to re-register in compliance with the new AR requirement to remain legally active in the market.

EPR Compliance Support with TBA Ecofuture

TBA Ecofuture provides comprehensive support to businesses navigating Germany’s complex EPR landscape. Whether you sell through your own platform or via marketplaces like Amazon, our services cover all three major German EPR categories: packaging, batteries, and WEEE.

We help ensure that your registration, reporting, and contribution fees are managed efficiently and in line with current regulations.

Packaging (VerpackG) Compliance Services

Our standard packaging EPR registration and reporting service is available for GBP 120 per year. This fee includes a basic usage allowance of 100 kg of paper and 10 kg of plastic packaging.

If your annual packaging usage exceeds this limit, the German packaging authority (LUCID) will charge additional fees based on your reported usage. These fees are applied separately and billed directly to you.

Battery (BattG) Compliance Services

For battery compliance in Germany, our standard registration and reporting service is priced at GBP 350. If you need to register additional battery categories or product brands, we offer this at an additional fee of GBP 150 per category or brand.

WEEE (ElektroG) Compliance Services

WEEE compliance is more complex due to the monthly reporting and mandatory use of an Authorised Representative for foreign sellers.

TBA Ecofuture offers full registration and reporting services tailored to your business location:

· For businesses based in Germany: GBP 700 annually

· For businesses based outside Germany: GBP 1,000 annually

This pricing includes:

· GBP 300 for registration, renewal, and ongoing reporting

· GBP 400 mandatory recycling contribution

· GBP 300 Authorised Representative fee (applies only to foreign entities)

If your business needs to register more than one product category or brand, the following additional fees apply:

· Additional product categories: GBP 480 per category

o GBP 80 registration/renewal fee

o GBP 400 recycling contribution

· Additional brands: GBP 200 per brand

o GBP 50 registration/renewal fee

o GBP 150 recycling contribution

All prices are annual and subject to review in line with regulatory updates.

Contact us to get your free consultation.