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I sell electronics online. Do I have to take back old devices from German customers?

Only if your storage and shipping areas for electrical equipment reach 400 m². Then you take back old devices free of charge.

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

Only above 400 m². § 17(2) ElektroG applies the take-back duty to distance sellers too, counting all storage and shipping areas for electrical equipment as the sales area. From 400 m² you must, free of charge: take back an old device of the same type when you deliver a new one (one-for-one), and take back very small devices (no side over 25 cm) on request, up to three per type, without a purchase. For categories 1, 2 and 4 the old device is collected from the household at delivery; for categories 3, 5 and 6 you provide suitable return points within reasonable distance. Below 400 m², take-back is voluntary (§ 17(3)). ElektroG § 17

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