How high are the fines under the German electronics law (ElektroG)?

Q: How high are the fines under the German electronics law (ElektroG)?

§ 45(2) ElektroG sets fines of up to €100,000 for the breaches listed in § 45(1) Nos 1 to 9, 12 and 13a, which include not registering, or not registering in time, before placing equipment on the market. Every other breach in § 45(1) can be fined up to €10,000. The Umweltbundesamt is the authority for most of them.

Up to €100,000 for the serious breaches, including selling without registration; up to €10,000 for the others (§ 45(2) ElektroG).

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

Up to €100,000. § 45(2) ElektroG: up to €100,000 for the breaches in § 45(1) Nos 1–9, 12 and 13a, starting with failing to register, or to register in time, under § 6(1); up to €10,000 for the rest. The Umweltbundesamt prosecutes most of them (§ 45(3)). Separately, an unregistered producer's goods may not be listed or fulfilled at all (§ 6(2)).

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