Under the relevant European Union law, selling electrical and electronic equipment in Germany requires close attention to the German Directive on Waste Electrical and Electronic Equipment (WEEE). Recently, cross-border e-commerce platforms such as Alibaba, Amazon and eBay have issued notices. According to these notices, Amazon will stop selling products that do not meet WEEE compliance requirements from 5 June 2023, while Alibaba and eBay will start phasing in controls on electrical and electronic equipment sold to Germany from 1 July 2023.

When selling products to German buyers, you must comply with extended producer responsibility (EPR) requirements. Business sellers must comply with the German Packaging Act and the Electrical and Electronic Equipment Act (EEE Directive). This policy applies to all business sellers whose products are shipped to addresses in Germany.

Information for business sellers on the German electrical and electronic equipment regulations
1. Who is affected by the electrical and electronic equipment rules
This policy applies to sellers resident in Germany and to sellers in other countries and regions who sell items to consumers in Germany. It also applies to sellers using the Global Shipping Program.

2. You must comply with the Electrical and Electronic Equipment Act and provide your WEEE number in your account if:
You are regarded as a producer or importer under the Electrical and Electronic Equipment Act;
You list electrical and electronic equipment within the scope of the regulations on Alibaba, Amazon and eBay;
The items you sell are for private consumers in Germany.
If you do not provide your WEEE number in your account, your listings on Alibaba, Amazon and eBay may be hidden. Once you add your WEEE number, the listings concerned will be restored.

3. Situations in which registration may be required
Non-German sellers, namely producers, manufacturers and importers without a branch in Germany who sell to German consumers by direct mail or by storing products in German warehouses in advance:
(1) if the product or brand has already been placed on the German market under the correct EAR category, verify this with EAR first;
(2) if the product or brand has not yet been registered, contact a third-party service provider for details so that it can be registered under the correct EAR category.
German sellers with their own brands (manufacturers and producers):
Register the brand under the correct EAR category and obtain a WEEE number.
German sellers acting as importers (with a branch in Germany):
(1) if the product or brand has already been placed on the German market under the correct EAR category, verify this with EAR first;
(2) if the product or brand has not yet been registered, register for WEEE and obtain a registration number.
If you do not have a branch in Germany, you must appoint an authorised representative responsible for fulfilling your legal obligations as a German producer. The authorised representative must be registered with EAR and apply for the necessary registrations on your behalf.

4. Which products require WEEE registration
1. Heat exchangers, for example refrigerators
2. Display devices, for example desktop computers
3. Lamps and gas discharge lamps
4. Large electrical equipment, for example massage chairs
5. Small electrical and electronic equipment, for example small speakers
6. Small IT and telecommunications equipment, for example mobile phones
Strictly speaking, the vast majority of electrical and electronic products require WEEE registration

5. WEEE registration steps
1. The seller completes the German recycling registration application form.
2. The recycling company drafts the recycling contract.
3. The seller signs and returns the contract.
4. The recycling company counter-signs the contract, which then takes effect.
5. The seller receives the invoice and pays.
6. The recycling company submits the contract and the seller registration documents to EAR for review.
7. After review, EAR issues the WEEE number and enters it into the German electronic recycling database.

6. Required documents:
Completed WEEE application form
Business licence
Identity card of the legal representative
One product image showing the logo
Product user manual

The upload deadline for the German WEEE number was originally set for January 2023. Following adjustments to German policy, it was extended to 1 July 2023, so sellers must pay attention to the impact of this policy.