Find out your obligations as a producer
Are you a producer of electrical and electronic equipment or batteries? Then you play an important part within the scope of the circular economy. In this guide you will find out which obligations and requirements you are facing, starting with the proper registration. We will explain to you, step by step, how you can fulfill your legal obligations and can contribute to the orderly disposal and take-back of electrical and electronic equipment and batteries.
Producer according to ElektroG is:
- The producer, that manufactures electrical and electronic equipment under his own name or his brand and sells them in Germany.
- A person who offers electrical and electronic equipment from other producers under his own name or brand in Germany, or resells these commercially. But: If the name or brand of the producer appears on the equipment, the person who offers or the reseller ar not seen as producer.
- An importer who offers electrical and electronic equipment that does originate from abroad for the first time on the German market.
- A person who sells electrical and electronic equipment to end users in Germany and is not situated in Germany.
A distributor who offers electrical appliances from unregistered manufacturers for sale without proper registration has the same responsibility as a producer.
Special producer constellations:
OEM
A producer who manufactures his products without placing his brand on it(i.e. Original Equipment Manufacturer – OEM) does not count as producer. Producer according to ElektroG is rather this producer’s customer who sells the product under his own brand.
Promotional product supplier
A supplier of promotional products can be registered as producer if he produces the electrical and electronic equipment on his own and labels it with his brand. If the supplier only produces under the brand of the customer, the customer ist the producer.
Assembler
Companies that only assemble the electrical and electronic equipment with different components (assembler), can cpunt as producer. If the assembler uses components for which the producer is registered in Germany, then the appropriate label on the components must be retained during assembly.
Producer according to Batteries Law is:
- The manufacturer/producer who manufactures batteries under its own name or brand, or has batteries designed or manufactured and supplies them for the first time under its own name or brand in Germany. This applies to batteries incorporated in appliances.
- Anyone who resells batteries of other manufacturers/producers under its own name or brand in Germany.
- An importer who supplies batteries from abroad on the German market for the first time.
- Anyone who sells batteries by means of distance contracts directly to end-users in Germany and is not established in Germany. This Producer has to mandate an autorised representative who fulfills the legal obligations.
Topics for producers according to Batteries Law
FAQs to find out obligations as a producer
In our FAQ section you can find answers to frequently asked questions.
No, registration in Germany according to ElektroG and Batteries Law is only valid in Germany, as each EU Member State has independently transposed the provisions applicable for registration into national law. Therefore a registration is only valid in the respective country.
Yes, as a registered ElektroG producer/ElektroG authorised representative you can, for example, vote on regulatory proposals that affect you or actively participate in so-called expert committees. Details can be found in the 'Gemeinsame Geschäftsordnung'.
No, participation is not mandatory, but ElektroG offers you as a registered ElektroG producer/ElektroG authorised representative rights to participate in stiftung ear as ‘Gemeinsame Stelle’. This gives you the opportunity to actively participate in implementing the law in certain areas.
Voting for elections and votes on rules and regulation plans only takes place electronically via the ear-Portal. You can participate in the vote via the respective task in your mailbox. Then the ear-Portal will lead you through the voting procedure.