By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Yes. § 3 No. 9(d) ElektroG counts as a producer anyone who offers electrical or electronic equipment by distance selling directly to end users in Germany while established in another EU country or a third country. § 8(2) then obliges you to appoint an authorised representative (Bevollmächtigter): one only, appointed in writing and in German (§ 8(1)). Under § 6(1) the registration by brand and device type has to be in place before the equipment is placed on the market. We act as your WEEE representative for €500 a year. Sources (3)
ElektroG § 3ElektroG § 3ElektroG § 8ElektroG § 8ElektroG § 6ElektroG § 6
WEEE Germany authorised representative at stiftung ear for foreign companies: the steps
stiftung ear is the joint body of producers, entrusted under § 40 ElektroG with the registrations the Umweltbundesamt would otherwise handle. A foreign company gets registered in five steps:
| Step | What happens | Rule |
|---|---|---|
| 1. Mandate | You appoint one representative, in writing and in German, for at least three months | § 8(1) and (2) ElektroG |
| 2. Naming | The representative is named to stiftung ear with a copy of the mandate; the naming takes effect once confirmed | § 8(3) |
| 3. Registration | Per brand and device type, with proof of the guarantee for household equipment or the credibility statement and take-back concept for B2B equipment | § 6(1), § 7 |
| 4. Registration number | Shown on every offer and invoice, including marketplace listings | § 6(3) |
| 5. Reporting | Quantities per device type by the 15th of each month, or yearly by 30 April for B2B equipment | § 27 |
Steps 1 to 3 must be complete before the first device is offered: until then marketplaces may not list it and fulfilment centres may not ship it (§ 6(2)). See what it costs.
ElektroG § 40 ElektroG § 6 ElektroG § 7 ElektroG § 8 ElektroG § 27 ElektroGBattDGGebV, fee sche
What stays with you
- The data. You give your representative the monthly quantities per device type; it files them (§ 27).
- The marking. Producer identification, date marker and the crossed-out wheelie bin on each device (§ 9): see marking.
- The guarantee for household equipment, renewed every calendar year (§ 7).
- Batteries inside the devices, which need their own registration: see batteries built into devices.
ElektroG § 27 ElektroG § 9 ElektroG § 7
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