Does the WEEE directive apply directly to my webshop?

No. Directive 2012/19/EU is addressed to the member states and only binds sellers through national implementing law. In Germany, that is the ElektroG with registration at stiftung ear; in Austria, the EAG-VO with reports via the EDM portal. What applies in your case depends on the equipment, your role and the target country.

Do I count as a producer if I sell other producers' equipment under my own name?

Yes, as a rule. Under § 3 No. 9 ElektroG, a producer is also anyone who offers equipment from other producers under their own name or brand. A typical case is extending your range with an own-brand line: if the brand on the equipment changes to yours, you take on the producer role, even without your own production. Conversely, if the original producer's name stays on the equipment, you are a distributor and not automatically a producer.

Does a WEEE registration in Germany cover all of Europe?

No. Every member state runs its own register: the German registration with stiftung ear only applies to Germany, and in Austria registration runs via the EAG-VO and the EDM portal. For every further target country, the check must be repeated separately.

Do I have to be registered before I sell the first device?

Yes. Electrical equipment may not be placed on the market without proper registration. Distributors may not offer equipment from unregistered producers; online marketplaces may not enable such offers, and fulfilment service providers may not provide certain services. Plan for the registration time before your intended sales launch.

Does the planned WEEE revision already change anything for me?

No. The European Commission has announced a Circular Economy Act for 2026, in which the further development of European law on waste electrical equipment is also expected to play a part. No specific new legal act has been adopted yet. Until a legislative procedure has been concluded and implemented, current national law applies.

WEEE directive for electronics sellers: check each target country

Key takeaways

The WEEE directive 2012/19/EU does not bind sellers directly: registration and take-back obligations only arise through each target country's implementing law.
Anyone who offers electrical equipment under their own name or brand, or sells it from abroad by distance selling to end users in Germany, counts as a producer under § 3 No. 9 ElektroG.
Without an establishment in Germany, exactly one authorised representative is mandatory; § 8 ElektroG sets out the form and validity requirements for the appointment.
Germany implements the directive in the ElektroG with its register at stiftung ear, Austria in the EAG-VO with registration via the EDM portal: every check applies per target country.
The WEEE revision within the Circular Economy Act is an announced proposal, not an obligation in force: act on current law, not on the draft.

What does the WEEE directive regulate, and what is changing?

Directive 2012/19/EU on waste electrical and electronic equipment, the WEEE directive for short, governs the collection, treatment, recovery and take-back of waste electrical and electronic equipment in the EU. It does not bind sellers directly. Your obligations arise through the law of each target country in which you sell. That is the decisive point for your own check: the same directive leads to obligations under the ElektroG (Germany's Electrical and Electronic Equipment Act) in Germany and to obligations under the EAG-VO (Austria's Elektroaltgeräteverordnung, its WEEE ordinance) in Austria.

The directive sets three targets, which the German Environment Agency (Umweltbundesamt) reports for Germany: a minimum collection rate of 65% of the weight of equipment placed on the market in the three preceding years, in force since 2019; recovery rates of 75 to 85% per equipment category; and rates for recycling and preparation for re-use of 55 to 80%. Germany clearly missed the collection rate in 2024, at 28.7%. For you as a seller, this means that pressure on collection and checks is rising, but the obligations themselves do not change as a result.

For context on the ongoing debate: the European Commission has announced a Circular Economy Act for 2026.^[1] The further development of European law on waste electrical equipment is also expected to play a part in it. No specific new legal act has been adopted yet; existing WEEE law and national law therefore continue to apply to businesses.

Which of these obligations affect your business, and in which target countries, cannot be read off the directive in general terms. The ClearoSystems Digital needs analysis checks your combination of products, roles and sales channels against the law of the relevant countries and shows where action is needed.

Who counts as a producer under the WEEE directive?

The producer role decides who has to register, report and ensure take-back. In Germany, § 3 No. 9 ElektroG defines who is a producer.^[2] The definition follows the specific situation, not company size and not industry. Check which case applies to you.

Own manufacture or own brand: you manufacture equipment under your name or brand, or have it designed or manufactured, and offer it in Germany. Reselling own-brand goods also falls under this, as long as the name or brand of the original producer does not appear on the equipment.
First import: anyone who offers equipment originating from another member state or a third country on the German market for the first time also counts as a producer.
Distance selling from abroad: anyone established in another member state or a third country who uses means of distance communication, such as a webshop or marketplace, to offer equipment directly to end users within the scope of the ElektroG counts as a producer, regardless of the sales method.

Your own logo or a print on the equipment is a connecting factor, not an automatic trigger. What matters is that you offer the equipment under your own name or brand. If, on the other hand, you sell goods that carry the name or brand of the original producer, the producer role does not automatically fall to you; a distributor role may apply instead. Where the line falls depends on the specific supply and contract arrangement. This is exactly where the need for checks most often arises when you expand your range or add new suppliers.

Mind the terminology: the WEEE directive and the ElektroG use the term producer in a specific sense of their own. Other areas of obligation, such as packaging law, use different role terms. Check each area of obligation against its own definitions.

How do Germany and Austria implement the directive?

The WEEE directive is a directive. It only takes effect through national implementing law, and every country runs its own register. There is no EU-wide WEEE register. For your target countries, this means:

Germany: the Electrical and Electronic Equipment Act (Elektro- und Elektronikgerätegesetz, ElektroG) entered into force in October 2015 and implements Directive 2012/19/EU. Registration takes place with stiftung ear, the German WEEE register, per brand and type of equipment. According to stiftung ear, a complete and correct application in the ear portal usually takes between 2 and 4 weeks to process; equipment may only be placed on the market once the registration notice has been issued.^[3]
Austria: the Elektroaltgeräteverordnung (EAG-VO, the Austrian WEEE ordinance) implements the directive on the basis of the Waste Management Act 2002 (Abfallwirtschaftsgesetz 2002); the consolidated version was last amended by BGBl. II No. 218/2026. Obligated parties register under § 21 EAG-VO, reports are made via the environment ministry's EDM portal, and § 25 EAG-VO sets out the obligations of the direct importer (Eigenimporteur).^[4]

The specific German obligations in detail, from registration through labelling and quantity reports to take-back, are covered in our separate guide to the ElektroG. Other EU countries have their own procedures and registers; this article does not claim to cover all target countries.

When do sellers based abroad need an authorised representative?

A producer without an establishment within the scope of the ElektroG must appoint exactly one authorised representative. This expressly also applies to the distance-selling producer under § 3 No. 9 letter d ElektroG, for example a webshop based in the Netherlands or Austria that sells directly to private and commercial end users in Germany. The authorised representative is a person or company established within the scope of the Act that performs, in its own name, the tasks needed to fulfil the producer obligations.

The appointment must be made in writing and in German and must be effective for at least three months.
Each producer may appoint only one authorised representative.
The producer notifies the competent authority of the authorised representative without delay, enclosing a copy of the appointment; the notification requires confirmation by the authority.

§ 8 para. 5 ElektroG contains the mirror rule: anyone who makes equipment available directly to end users in another member state by distance selling from Germany must, before entering that market, appoint an authorised representative established there who is responsible for the WEEE obligations in that country. The authorised representative performs the producer obligations under the ElektroG in Germany in its own name. For this, the foreign producer must appoint a suitable authorised representative and notify the competent authority.^[5] As for registration itself: the authorised representative arranges the application for the WEEE registration for your brand and type of equipment; the details are covered in the guide to the WEEE number.

Which WEEE obligations apply in your target countries?

In practice, this means the check follows a fixed sequence. The internal decision logic for entering the German market shows the sequence that has proven itself in practice:

Clarify your role: do you place the equipment on the market for the first time under your own name or brand, do you import it, or do you sell it directly to end users in Germany by distance selling? Then you are probably an obligated producer.
Check the equipment and exemptions: is it finished equipment or only a component? Does an explicit exemption under the ElektroG apply? Without an exemption, the WEEE track is active.
Distinguish B2C from B2B: B2C in particular requires an insolvency-proof guarantee; the specific obligations on pick-up coordination and take-back also apply. For B2B, you must credibly demonstrate exclusively commercial use and submit a take-back concept.^[3] Registration, labelling and reports concern both areas but differ in how they are set up in detail.
Determine the target country: Germany leads to registration with stiftung ear and, without your own establishment, to appointing an authorised representative; Austria leads to registration under § 21 EAG-VO with reports via the EDM portal.

In cross-border e-commerce in particular, it is not enough to know that the WEEE directive exists. What matters is which specific obligations arise from it for your products and target countries. With the ClearoSystems Digital needs analysis, you get a complete overview of your EPR obligations by product, role, sales channel and country. That way, you spot missing registrations or authorised representative appointments early and avoid the sales restrictions and operational problems they would cause.

Frequently asked questions

Does the WEEE directive apply directly to my webshop?: No. Directive 2012/19/EU is addressed to the member states and only binds sellers through national implementing law. In Germany, that is the ElektroG with registration at stiftung ear; in Austria, the EAG-VO with reports via the EDM portal. What applies in your case depends on the equipment, your role and the target country.
Do I count as a producer if I sell other producers' equipment under my own name?: Yes, as a rule. Under § 3 No. 9 ElektroG, a producer is also anyone who offers equipment from other producers under their own name or brand. A typical case is extending your range with an own-brand line: if the brand on the equipment changes to yours, you take on the producer role, even without your own production. Conversely, if the original producer's name stays on the equipment, you are a distributor and not automatically a producer.
I sell from the Netherlands to Germany: do I need an authorised representative?: Yes. Anyone who sells directly to end users by distance selling without an establishment in Germany counts as a producer and must appoint exactly one authorised representative under § 8 ElektroG. The authorised representative performs the tasks; the producer obligation stays with your own company.
Does a WEEE registration in Germany cover all of Europe?: No. Every member state runs its own register: the German registration with stiftung ear only applies to Germany, and in Austria registration runs via the EAG-VO and the EDM portal. For every further target country, the check must be repeated separately.
Do I have to be registered before I sell the first device?: Yes. Electrical equipment may not be placed on the market without proper registration. Distributors may not offer equipment from unregistered producers; online marketplaces may not enable such offers, and fulfilment service providers may not provide certain services. Plan for the registration time before your intended sales launch.
Does the planned WEEE revision already change anything for me?: No. The European Commission has announced a Circular Economy Act for 2026, in which the further development of European law on waste electrical equipment is also expected to play a part. No specific new legal act has been adopted yet. Until a legislative procedure has been concluded and implemented, current national law applies.