Does this apply to my business?

If your company is established in the Netherlands, has no branch in Germany, and sells electrical equipment or batteries into the German market, you cannot register directly with stiftung ear. You must appoint an authorised representative in Germany to assume your legal producer obligations.

What exactly do I have to register or report?

Your representative applies for your WEEE registration with stiftung ear and manages the ongoing reporting interfaces. However, you are still responsible for providing the correct product data, tracking the volumes you place on the market, and covering the associated fees and guarantee requirements.

What happens if I am late?

Failing to appoint a representative and register on time means you are operating illegally. This can result in immediate sales bans, costly warning letters from competitors, and substantial administrative fines from the German authorities.

Can I switch my authorised representative?

Yes, but you can only have one active authorised representative at a time. The mandate with your current representative must be formally terminated via the ear-portal before the new representative's authorisation can be confirmed by the authority.

Does one representative cover both WEEE and batteries?

A single representative can handle both your WEEE and battery registrations, provided they offer both services. Since the German battery register is also managed by stiftung ear, using the same partner for both obligations is common practice.

Can I sell before the registration is complete?

No. Selling electrical equipment or batteries in Germany before your authorised representative has successfully completed your stiftung ear registration is strictly illegal and will lead to immediate sales bans.

Do marketplaces check my WEEE registration number?

Yes. Marketplaces are legally obligated to verify your WEEE registration number before allowing you to sell electronics in Germany. If you cannot provide a valid number obtained through your authorised representative, your listings will be blocked.

When do you need an authorised representative in Germany?

Who needs one: no German establishment plus electronics

If your Dutch company sells electrical or electronic equipment directly to German buyers and has no registered branch in Germany, you cannot register directly with the German register stiftung ear. Under the German Electrical and Electronic Equipment Act (ElektroG), foreign producers must appoint an authorised representative (Bevollmächtigter) established in Germany to take over producer obligations in their own name. Packaging used to be the exception, and it no longer is. Since 12 August 2026 the PPWR and the German Packaging Law Implementation Act (VerpackDG, which replaced the Verpackungsgesetz) apply together, and the Zentrale Stelle Verpackungsregister states that a producer without a German establishment must name an authorised representative in LUCID before making packaging or packed goods available on the German market for the first time: without those details the registration cannot be completed.^[3] Filing the registration stays your own act, because the declarations it requires may not be submitted by a third party.

In the Netherlands, you fulfil your electronics obligations through Stichting OPEN and the ^[3]Nationaal (W)EEE Register without needing an external representative. Cross-border sales into Germany run on a separate national track, and the reason the German registers give is the same in all three regimes: a producer they can reach in Germany has to carry the statutory duties before the goods reach the market.

No German branch: Your business is established solely outside Germany, with no commercial register entry or permanent operational establishment in Germany.
Direct cross-border sales: You sell electrical goods, electronics, or battery-containing items directly to German consumers (B2C) or end-users (B2B) via distance selling.
Mandatory representative: You must appoint an authorised representative established in Germany before offering or distributing products in the German market.

If your cross-border setup sits on the edge of these criteria or involves multiple sales channels, assessing your distribution model early prevents distribution stops on German sales channels.

The scope test: which of your product flows trigger it

Not every cross-border shipment into Germany triggers an authorised representative requirement. The obligation depends on the specific regulatory regime, the product category, and the commercial delivery terms agreed between you and your customer.

EPR regime	Trigger for Dutch seller	Authorised representative required?	Registration authority
WEEE (ElektroG)	Finished electrical and electronic equipment sold directly to German end-users	Mandatory for foreign producers with no German branch	stiftung ear
Batteries (BattDG)	Portable, SLI, electric vehicle, LMT or industrial batteries placed on the German market	Mandatory for producers obliged to register who have no seat of their own in Germany^[1]	stiftung ear
Packaging (PPWR + VerpackDG)	Sales, grouped, or shipping packaging accumulating in Germany	Mandatory since 12 August 2026 for sellers abroad without a German branch, with the LUCID registration itself remaining your own personal duty^[3]	ZSVR / LUCID

To determine whether an authorised representative is legally mandatory for your business, you can check your sales setup against one explicit no-case based on commercial delivery terms:

Ex Works (EXW) sale in the Netherlands: If a German business customer purchases electronic goods under EXW terms, takes physical ownership at your Dutch warehouse, and handles the transport across the border, that German buyer acts as the primary importer placing the goods on the German market. In this constellation, the Dutch seller does not qualify as the initial German distributor and requires no German authorised representative.
Delivered Duty Paid (DDP) or direct B2C dispatch: If your Dutch webshop delivers electrical goods directly to German consumers or commercial end-users via distance selling, you remain the responsible party placing the equipment on the German market and must appoint a representative.

Evaluating these operational triggers across your electronic product range clarifies which product flows require active representation before market entry.

Step-by-step: appointing a representative and registering

Appointing an authorised representative is a formal administrative process with stiftung ear. The mandate transfers statutory producer duties under ElektroG to the representative, while your brand name is registered and published on the official register.

Mandate a German representative in writing: You conclude a written contract in the German language with an authorised representative established in Germany, signed by both parties. Under stiftung ear rules, an ElektroG authorised representative must be mandated for a minimum of three months^[4].
Account setup and verification: The representative submits the mandate agreement through the ear-Portal. Stiftung ear reviews the documentation and officially confirms the representative status.
Application for brand and equipment type: The representative files registration applications for your specific brand and equipment categories (such as small IT equipment, lighting, or consumer electronics) and submits the required financial guarantee for B2C equipment.
Issuance and publication of your WEEE number: Stiftung ear issues the registration notice and assigns a distinct WEEE registration number. The entry is publicly listed in the German register of producers, confirming that the representative acts on behalf of your Dutch company.

Once the registration notice is granted, you can legally list and distribute your electronic products in Germany and submit the WEEE number to marketplaces.

Key figures and timelines: fees and registration duration

Securing an authorised representative and completing registration involves statutory administrative fees and a disposal guarantee that must be budgeted before launching sales in Germany. Stiftung ear publishes its fee schedule under the ElektroGBattDGGebV, and the amounts below are the net figures from it^[5]; VAT is added on top.

Cost / timeline element	Statutory basis or parameter	Published amount, net of VAT (2025/2026)
Confirmation of representative	Fee item 1.7 under ElektroGBattDGGebV	EUR 50.60 one-off per represented producer
Registration fee (ElektroG)	Fee item 1.1 under ElektroGBattDGGebV	EUR 9.50 one-off per brand and equipment type
Quarterly fee (ElektroG)	Fee item 1.2 under ElektroGBattDGGebV	EUR 32.80 per quarter for administrative maintenance
B2C financial insolvency guarantee	Annual guarantee proof for potential return and recycling costs	Calculated based on equipment type, planned tonnage, and guarantee system
Registration processing time	Administrative examination by stiftung ear	No processing time is published; track the status in the ear portal and check the public producer register for your entry

Responsibilities after appointment: who does what

Appointing a representative creates a continuous division of labour. The representative provides the legal entity in Germany, interfaces with stiftung ear, files monthly and annual volume reports, and coordinates disposal pickup orders. Your Dutch business remains responsible for providing timely product master data, reporting actual sales weights, and funding the administrative and dual-system fees.

Outlook: how the rules develop from here

Extended Producer Responsibility regulations continue to evolve across the European Union. The provisions of Regulation (EU) 2023/1542 have largely been applicable in the member states since 18 August 2025^[6], and Germany adapted its national battery law accordingly: the Battery Law Implementation Act (BattDG) entered into force on 7 October 2025^[2], with the German Environment Agency again designating stiftung ear as the authority for producer registration^[6]. The packaging side moved in the same direction and has already arrived: since 12 August 2026 a distance seller without an establishment in Germany has to name an authorised representative in LUCID, so all three regimes now point at the same answer^[3].

Because European and national rules are updated in continuous cycles, requirements that apply today may shift as secondary legislation takes effect. What remains constant is that compliance depends on your exact operational profile.

Which obligations apply in each country depends on your exact role in the chain and on where you are established: importer, own-label seller, or reseller, with or without a local establishment, each lands differently per country. These distinctions cannot reliably be resolved through a general checklist alone. Our Digital needs analysis evaluates your specific setup and identifies which requirements actually apply to your business.

To understand your compliance position today and be on the safe side, start the digital needs analysis with ClearoSystems now. Afterwards, our experts support you in implementing the requirements and keep you covered as the rules evolve.

Frequently asked questions

Does this apply to my business?: If your company is established in the Netherlands, has no branch in Germany, and sells electrical equipment or batteries into the German market, you cannot register directly with stiftung ear. You must appoint an authorised representative in Germany to assume your legal producer obligations.
What exactly do I have to register or report?: Your representative applies for your WEEE registration with stiftung ear and manages the ongoing reporting interfaces. However, you are still responsible for providing the correct product data, tracking the volumes you place on the market, and covering the associated fees and guarantee requirements.
What happens if I am late?: Failing to appoint a representative and register on time means you are operating illegally. This can result in immediate sales bans, costly warning letters from competitors, and substantial administrative fines from the German authorities.
Can I switch my authorised representative?: Yes, but you can only have one active authorised representative at a time. The mandate with your current representative must be formally terminated via the ear-portal before the new representative's authorisation can be confirmed by the authority.
Does one representative cover both WEEE and batteries?: A single representative can handle both your WEEE and battery registrations, provided they offer both services. Since the German battery register is also managed by stiftung ear, using the same partner for both obligations is common practice.
Can I sell before the registration is complete?: No. Selling electrical equipment or batteries in Germany before your authorised representative has successfully completed your stiftung ear registration is strictly illegal and will lead to immediate sales bans.
Do I need a representative for packaging as well?: Yes, since 12 August 2026. A producer without an establishment in Germany has to name an authorised representative in the LUCID register before making packaging or packed goods available on the German market, and the registration cannot be completed without those details. Filing the LUCID registration itself remains your own act and cannot be handed to a third party.
Do marketplaces check my WEEE registration number?: Yes. Marketplaces are legally obligated to verify your WEEE registration number before allowing you to sell electronics in Germany. If you cannot provide a valid number obtained through your authorised representative, your listings will be blocked.