Registration at Stiftung Elektro-Altgeräte-Register
Two million tons of electronic waste accumulated in Germany in 2019. High time, then, to enshrine higher standards for environmental protection in law and to involve manufacturers in disposal. In Germany, the Stiftung Elektro-Altgeräte-Register (ear) is tasked of preventing damage to the environment and health caused by batteries, electrical and electronic equipment. Among other things, it has the power to receive, check and publish registrations, as well as to check guarantees, determine guarantee systems, record the quantities placed on the market, etc.
Why do you have to be registered?
The Battery Act and the Electrical and Electronic Equipment Act require registration with the ear Foundation, thereby replacing the requirement to report to the Federal Environment Agency. The purpose of registration is to ensure compliance with legal requirements and to enable the enforcement of penalties for violations using the WEEE number. In this way, the legislature fulfills its responsibilities regarding environmental protection and the implementation of European Directive 2006/66/EC.
Who is required to register?
You must register with ear if you are a manufacturer of portable batteries, as well as industrial and automotive batteries, as defined by the ElektroG. The weight, composition, size, and intended use are irrelevant; the only exceptions are batteries intended for military use and those used in spaceflight. You are considered a manufacturer both if you have the batteries manufactured within your own company and if you place them on the German market. Therefore, if you import a battery that is not already registered in Germany, you are considered a manufacturer.
The Battery Act also applies to batteries that are installed in electronic or electrical devices. The electrical devices themselves, however, are subject to the Electrical and Electronic Equipment Act, including its disposal regulations. You are considered a manufacturer subject to registration under the ElektroG if you have electrical or electronic equipment manufactured under your own name or brand in Germany or another country and subsequently sell it in Germany. You are also considered a manufacturer if you label equipment from another producer with your name or brand and sell it in Germany. Similar to the Battery Act, the definition of “manufacturer” under the ElektroG has been extended to include importers who place a product on the market in Germany for the first time.
You need an authorized representative as defined by the Battery Act and the Electrical and Electronic Equipment Act if you are considered a manufacturer based on the aforementioned criteria but do not have a branch office in Germany. The so-called ElektroG authorized representative acts on your behalf with regard to your legal obligations as a manufacturer and, among other things, applies for ear registration on your behalf. For the authorization to be valid, it must meet a number of requirements.
What is required for ear registration, and how does the process work?
The registration process is an administrative procedure. This means that it is initiated only upon your application or that of your authorized representative. You are personally responsible for submitting the application. To submit the application via the stiftung ear portal, you must specify the type and brand of the battery or device you distribute. If you are unsure about the type, you must provide product photos and a description. If you meet the requirements for ear registration, you will receive a notification to that effect and a WEEE number, which identifies you as the distributor of the electrical or electronic product.
The Foundation for the Register of Waste Electrical and Electronic Equipment (ear) is a German foundation based in Fürth that has been working since 2004 on behalf of the Federal Environment Agency to implement the Electrical and Electronic Equipment Act and the Batteries and Accumulators Act. To achieve this goal, the foundation provides the infrastructure for registration. It also organizes the collection of waste equipment at public recycling centers and provides the necessary containers.
EAR registration by CERTIFY
An ear registration requires expertise and experience—for example, to correctly identify the device type of your electronic or electrical appliance. In addition, as a distributor of products intended for private end users, you must provide a guarantee to the ear Foundation. At CERTIFY, as part of our full-service offering, we handle the entire registration process for you, ensure that your reporting obligations are met, and communicate with all relevant authorities. Furthermore, we offer a certified and collective warranty system through which you can register your electrical and electronic equipment. We operate not only in Germany but also internationally, helping you overcome language barriers and legal pitfalls so that you can establish your products in various markets in compliance with the law. Contact us now and let our experts advise you!
FAQ: Important questions about ear registration
The official estimate is 8–12 weeks from the date the application is submitted in full. In practice, 12–16 weeks is typical because an insolvency-proof guarantee must be obtained, an authorized representative must be appointed (for foreign companies), and the disposal plan must be filed.
Anyone who wants to sell products during the Q4 sales season should begin the process by June at the latest. Early sales approval is not possible—without a WEEE number, sales are not legal.
Manufacturers of B2C electrical appliances must post a security deposit annually. Acceptable forms of security include a bank guarantee, an insurance guarantee, or an escrow account.
The amount is based on the previous year’s volume multiplied by a factor specific to the type of equipment.
The warranty is valid for the calendar year (January 1–December 31) and must be renewed annually—regardless of the registration date. Anyone who registers in November pays the full annual warranty fee.
Since 2022, Amazon has been actively verifying EPR compliance across all EU marketplaces. For the German marketplace (amazon.de), the following must be uploaded:
- WEEE number from the ear Foundation (for electrical appliances and battery-powered products)
- LUCID registration number from the Central Packaging Register
- BattG Number (for batteries and rechargeable batteries)
The numbers are stored in Seller Central under the Compliance Portal and are automatically cross-checked against government registries. If a number is missing or inactive, the affected ASIN listing will be deactivated within a few days.
How it works in practice:
- First warning via email with a deadline (often 30 days)
- If there is no response: Deactivation of the affected ASINs
- In the event of repeated non-compliance: Suspension of the entire seller account in the respective EU region
Reactivation typically takes 3–10 business days after the registration documents are submitted—but only if the numbers are actually active. A pending registration application is not sufficient.
Immediate actions, in this order:
- Identify the exact basis for the restriction—is it WEEE, the Packaging Act, the Battery Act, or a combination of these?
- Request express registration—some procedures can be expedited to 4–6 weeks if the required documents are available immediately
- Notify the marketplace about the ongoing registration process—some platforms grant grace periods if the process is documented
- Maintain stability in the inventory and supply chain during the shutdown so that we can resume deliveries immediately upon reactivation
CERTIFY prioritizes such emergencies and handles communication with authorities in parallel with communication on the Marketplace.