What is the German EEE Act?
When you sell items to buyers in Germany, you must follow the requirements of the Extended Producer Responsibility (EPR). eBay business sellers are obliged to be compliant with the Packaging Act and the Waste Electrical and Electronic Equipment Directive (WEEE Directive), which was implemented in Germany via the Electrical and Electronic Equipment Act (ElektroG).
The primary goal of the legislation regulating production and sale of Electrical and Electronic Equipment (EEE) is the responsibility of sellers and manufacturers for their product and its components life cycle, including recycling and disposal. It’s an essential condition for conserving raw materials, limiting greenhouse gas emission, and climate protection.
eBay has a legal obligation to ensure that all its B2C sellers in scope of these regulations are compliant with the Packaging Act, and for those selling electrical and electronic equipment, also with the EEE Act. Once you have registered with the respective authorities, you will receive a license and so-called "Lucid Number" for packaging waste and a “WEEE number” for electronic waste. If you do not submit your Lucid number or your WEEE number to your eBay account, eBay will be legally required to remove your listings for the German market. This page will provide you with details of what you need to do in relation to the EEE Act.
Who is affected by the German EEE Act?
You will need to fulfill compliance requirements and submit your WEEE number to eBay if:
- you are considered a producer or importer under the EEE Act and
- you list electrical and electronic equipment within the scope of the Act at eBay and
- your items will end up with private consumers in Germany
If you do not have a branch in Germany, you must appoint an authorized representative to be responsible for fulfilling your legal obligations as a producer in Germany. This authorized representative needs to be registered with the Foundation for registration of electrical and old appliances (Stiftung Elektro-Altgeräte Register, Stiftung EAR) and would apply for the necessary registrations on your behalf.
The WEEE number, which will be stored on eBay, indicates the manufacturer number assigned to those who place an EEE on the market for the first time after successfully registering in the EAR system. The valid WEEE numbers consist of a country code and a sequence of 8 numbers (for example, DE 12345678).
eBay listings in the electronics category requiring a WEEE number will be removed from ebay.de, if no WEEE number has been added at account level. Once your registration number has been added and verified, you will have to relist your items. This policy applies to sales to German buyers by sellers residing in Germany as well as those selling from abroad.
What do you have to do?
- If you already have a WEEE number, please submit it to your eBay account. This way it can automatically be displayed in your listings
Submit your WEEE number now
Add WEEE number to your ebay.de account
- If you don’t have a WEEE number yet, and you don’t know if you need one, check on the EAR Foundation website if you fall in scope of the law
- Manufacturers, producers or importers with a branch in Germany can register directly with the EAR Foundation or via a third party representative (Interzero)
Register directly with EAR Foundation
Reach out to a third party representative (Interzero)
- Manufacturers, producers or importers without a branch in Germany need to contact an authorized representative, approved by the ear Foundation, to register their Devices in the right ear category and sub category
Learn more about authorized representatives
eBay listings in the electronics category requiring a WEEE number will be hidden on ebay.de, if no WEEE number has been added at account level. Once their registration number has been added, the listing will be displayed again.
eBay's partner for EPR is Interzero, the licensing platform of the dual system company Interseroh+. Their experienced team will be able to provide any guidance you need.
Visit the Interzero — WEEE page to find out more.
Head of Digital Platform & Sales Interzero EPR
Interzero EPR Services GmbH
Mobil: +49 151 11691661
Examples of EEE sellers and devices
EEE device type examples
Details about the products the law applies to are on the EAR Foundation page.
- Heat exchangers — temperature exchange equipment: fridges, freezers, air conditioning, heating pumps, etc.
- Monitor devices — screens, monitors and equipment containing screens (>100cm² ): monitors, TV sets, tablets, etc.
- Gas discharge lamps: discharge lamps, fluorescent tubes
- Lamps: LED lamps (also with additional functions)
- Large devices: dishwasher, ventilation system, washing machine, oven, electric cooker, vacuum cleaner, mower, luminaires, copying equipment, large medical devices, musical equipment, etc.
- Large photovoltaic modules: photovoltaic modules with at least one external dimension of more than 50 cm
- Small photovoltaic modules: photovoltaic modules without external dimension of more than 50 cm
- Small devices: all other types of electrical and electronic equipment smaller than 50 cms (length, large or width): hifi, hair dryer, blender, mixer, electrical toy, drill, shaver, watches, smoke detectors, video cameras, thermostats, device with integrated photovoltaic panel, etc.
- Small IT and telecommunication equipment: all IT and telecom devices that are smaller than 50cms (length, large or width): smartphone, router, desktop, printer, wires, set top box, GPS, VHF radio, etc.
Possible sellers in scope
- German sellers with own brand (manufacturer/producer):
Register the brand in the correct ear category/categories and receive a WEEE number.
- German sellers who are Importers (with a branch in Germany):
- Check first with the EAR Foundation if the products/brands have been introduced already to the German market in the correct ear categories
- If not, register for a WEEE number
- Non-German Sellers (producers, manufacturers, importers without a branch in Germany who sell via dropship or have products already stored in warehouses in Germany):
Manufacturers, producers or importers without a branch in Germany need to contact an authorized representative, approved by the ear Foundation, to register their Devices in the right ear category and sub category
Frequently asked questions
I do not sell any EEE items at the moment. Do I have to register and provide a WEEE number?
If you do not sell any items from the affected categories, you don’t have to register and provide a WEEE number. However, please make sure that the items that you sell are indeed not covered by the regulation. In case of any doubts, please reach out to your tax advisor or check this with eBay’s partner Interzero.
Is there a “how to” video on the subject?
Do I need to have special labels?
Electrical and electronic equipment within the scope of the EEE Act must be permanently labeled in such a way that it is clear who the producer of the equipment is.
The crossed-out wheelie bin symbol must be permanently attached to the product. In exceptional cases due to the size or function of the equipment, the symbol must be printed on the packaging, the user instructions or the guarantee certificate instead of on the equipment.
Do I have the obligation to inform private households about recycling electrical and electronic equipment?
Yes. Since 1 January 2022, it has been mandatory to enclose the below information in writing with the electrical and electronic equipment:
- Obligation to collect waste equipment separately
- Obligation to remove old batteries/accumulators and lamps from waste equipment before returning it (if this is possible without destroying the waste equipment and no reuse is intended)
- Description of the take-back obligations of distributors
- Information on the producer's own take-back offers for waste equipment
- Consumers' own responsibility to delete personal data from the waste equipment to be disposed of
- Meaning of the wheelie bin symbol on waste equipment
I use the Global Shipping Program. Do I have to register and provide a WEEE number?
Registration in accordance with the EEE directive is also required when using the Global Shipping Program.
I only sell used electronic equipment. Do I still have to register?
- If the used electronic equipment that you sell comes from abroad and you are selling them in Germany for the first time:
You — as a manufacturer — must apply for your individual WEEE registration number for this equipment
- The used electronic equipment comes from Germany:
You do not need your individual WEEE registration number if you are not selling the equipment under your (brand) name
I am a “reseller” of a certain brand and this brand uses the WEEE number itselfs. Do I have to register and provide a WEEE number?
Yes, you are also required to register and provide a WEEE number irrespective if the brand itself has taken a WEEE number as eBay does not allow other registered WEEE numbers to be added on seller’s eBay account. If you are selling items from several brands, you need to register a WEEE number for each brand separately.