Generally, a producer is responsible to decide himself whether his products are in scope of the, or repsectively, if he fulfills the producer definition. In individual cases it can be difficult, though. Therefore, in cases of doubt, it is possible to apply for a binding chargeable certification of the obligation to register at stiftung ear (Assessment application).
A producer/authorised agent can submit an assessment application in the ear-Portal after creating an applicant’s account. Hereby it is necessary for the producer/authorised agent to briefly explain and justify why they think this is a case of doubt and to describe in detail the product, especially its utilistaion.
You can find more information on the fees for an assessment application at.