Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
One product, three separate regimes. The packaging is registered in LUCID under the VerpackDG; the speaker itself falls under the ElektroG, registered at stiftung ear by type of equipment and brand; the built-in battery falls under the BattDG, registered by brand and battery category. A producer with no German establishment needs a representative for each. Sources (2)
VerpackDG § 5VerpackDG § 5ElektroG § 6ElektroG § 6
Illustrative example. This is not one of our clients: the business is invented, while the law and our published prices are real.
The situation
A company in the United States sells portable Bluetooth speakers with built-in rechargeable batteries, through its own store and Amazon.de, to German consumers.
What applies
| Regime | Register | What it covers |
|---|---|---|
| Packaging (VerpackDG) | LUCID, by the producer itself | Box, inserts, shipping packaging |
| Electricals (ElektroG) | stiftung ear, through the representative | The speaker, by type of equipment and brand |
| Batteries (BattDG) | stiftung ear, through the representative | The built-in battery, by brand and category |
Equipment usable in private households also needs an insolvency-proof guarantee every calendar year, passed on at cost. See electronics: separate registrations.
ElektroG § 6 ElektroG § 7 BattDG § 5
Order of work
- Mandates for the three regimes.
- Registration at stiftung ear for the equipment and the battery before the first sale: neither may be placed on the market without it.
- LUCID registration and the dual-system licence for the packaging.
What it costs
Our published fees: €149 a year for packaging, €500 a year for electricals, €500 a year for batteries, with no setup fee. The guarantee, scheme and licence fees are passed on at cost. See pricing.
Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
Razvan on LinkedIn ↗