ElektroG WEEE ZSEE – Germany
International sales through Amazon, eBay, or your own online store isn’t just about preparing and optimizing your offer, organizing logistics, and providing top-level customer service.
It also involves obligations related to the local law of the country you’re selling to. Germany leads the way here, having many systems that require registration and being at the forefront of enforcing registration obligations. Since the beginning of the year, Germany launched the VerpackG system, which forced registration of entities introducing packaging into Germany.
Despite very high penalties for failing to register with the system and a large amount of information about the VerpackG/LUCID/ZVSR system available online, less than 30% of all entities with this obligation have registered so far (June 2019).
Unfortunately, these statistics are even worse for companies that are required to register with the ElektroG system.
ElektroG / ZSEE / WEEE is a system where companies introducing electronic and electrical equipment into Germany are required to register. WEEE (ZSEE) stands for Waste Electrical and Electronic Equipment. The system covers all electrical and electronic devices, including battery-powered ones.
The system applies to practically every manufacturer, distributor who ships equipment from Poland under their own brand, or first introduces equipment from a manufacturer who hasn’t registered with the ElektroG system to the German market.
Definition of equipment manufacturer according to the ElektroG document:
“Manufacturer:
- the producer, i.e., the one who manufactures electrical and electronic equipment (electrical devices) under their name or brand themselves or has them designed or manufactured and offers them under their name or brand in Germany (§ 3 Number 9 a) aa) and bb) ElektroG).
- the one who offers electrical devices from other manufacturers under their own name or brand in Germany or commercially resells them.
The provider or reseller is not considered a manufacturer if the name or brand of the manufacturer according to § 3 Number 9 a) ElektroG appears on the electrical device (cf. § 3 Number 9 b) ElektroG). - who, as part of commercial activity, first offers electrical devices that do not originate from Germany – but from a third country or another EU member state – on the German market (§ 3 Number 9 c) ElektroG). Thus, an importer can also be a manufacturer within the meaning of ElektroG.
- who offers electrical devices directly to end users using telecommunications means and is not established in Germany (§ 3 Number 9 d) ElektroG).
Equivalent to a manufacturer under ElektroG is the one who, as a distributor, culpably (intentionally or negligently) offers for sale electrical devices from unregistered or improperly registered manufacturers or from foreign manufacturers whose authorized representatives are not or are not properly registered (§ 3 Number 9 d) second half-sentence ElektroG).”
The system is quite complex, requiring monthly reports and informing contractors about being a member of the ElektroG registry by placing the WEEE number on commercial documents. Additionally, a certain difficulty for companies from Poland may be that a German representative is required for the WEEE registry. Not all companies handling ElektroG offer the service of representing a foreign company before Stiftung EAR. A representative is an additional paid service.
Fees associated with participating in the ElektroG program are not particularly high, but for companies from Poland they increase significantly due to the costs of a representative and their approval at Stiftung EAR.
If you need help with ElektroG, want to register your company with Stiftung EAR, feel free to contact us.
In cooperation with our partner from Germany, we’ll prepare an attractive offer for system registration and management for your company.
