Authorised representative for batteries and WEEE in Germany - entrust us with your EPR responsibilities

Foreign entrepreneurs who sell certain product categories to customers in Germany have to comply with a number of obligations under the German EPR regulations. One of these is the need to establish an authorised EPR company representative to take responsibility for fulfilling the obligations with regard to electrical equipment, batteries and accumulators.

EPR regulation in Germany - what do you need to know?

The Extended Producer Responsibility (EPR) system in Germany was introduced in implementation of EU Directives 94/62/EC on packaging and packaging waste, 2006/66/EC on batteries and accumulators (ob. Regulation 2023/1542) and 2012/19/EU on waste electrical and electronic equipment (WEEE).

German The following product categories are covered by the EPR:

  • under the ElektroG Act - electrical and electronic equipment (WEEE, WEEE),
  • under the BattG Act - batteries and accumulators,
  • under the VerpackG Act - packaging and packaged products.
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Traders who place the listed packaging and products on the German market must perform multiple duties, which aim to ensure that the waste generated is properly managed. These obligations include:

  • registration with the relevant authorities (German Clearing House - EAR for batteries, accumulators and electrical and electronic equipment, ZSVR-LUCID for packaging) in order to obtaining an EPR number,
  • cyclical reporting volumes of products and packaging introduced to the German market,
  • organisation of waste collection produced from introduced products (via an extended producer responsibility organisation),
  • information obligation (appropriate labelling of packaging and products, information on the collection system),
  • for companies not based in Germany that introduce batteries and equipment: establishment of an authorised representative for the EPR.

Who is the authorised representative for EPR in Germany?

An authorised representative for an EPR is a natural or legal person who assumes the manufacturer's obligations under the EPR in Germany (ElektroG, BattG, VerpackG). The scope of these duties mainly depends on the type of products or packaging being introduced into the German market.

A manufacturer's authorised representative may only be an entity that is established in Germany, has been entered in the relevant register (LUCID, EAR) and has concluded a written agreement with the manufacturer transferring the obligations arising from the EPR regulation.

Who must appoint an authorised company representative for EPR in Germany?

The establishment of an authorised EPR representative in Germany is mandatory for all companies that without being established in Germany, place on the German market:

  • batteries and accumulators,
  • products containing batteries or accumulators,
  • electrical and electronic equipment (EEE).

An authorised representative must therefore be in place for foreign entities that sell products directly to individual customers in Germany for via distance selling channels (their own online shops or sales platforms such as Amazon, eBay, Zalando, etc.).

The need to appoint an authorised representative does not yet extend to companies selling packaging and packaged products into Germany. This obligation will not come into force until August 2026, when the PPWR regulation (Packaging and Packaging Waste Regulation) However, these entrepreneurs can voluntarily appoint an authorised EPR representative in order to save time and gain confidence that all their duties are being carried out correctly and in a timely manner.

Authorised representative for EPR in Germany - choose the best offer

Are you required to establish an authorised EPR representative in Germany? Do you want to delegate your tasks to a trustworthy company that will fulfil them with the utmost care? Sign a contract with Interzero! As an environmental consulting company with more than 30 years of experience we will provide you with comprehensive, professional support and relieve you of tedious duties.

By choosing Interzero as your authorised EPR representative in Germany:

  • you will delegate all your responsibilities resulting from the EPR regulations in Germany,
  • fast and hassle-free obtain all the data and documents required by the major sales platforms,
  • save time for yourself and your employees,
  • you will be able to sell your products safely and completely legally German customers,
  • you will be assured that the waste from your products is treated with respect for the environment.

Fill out a short questionnaire and find out a quote for your company's services >>

Sign a contract with Interzero in a few simple steps

In order to make it easier for businesses to meet their obligations under the EPR regulations, our clients we offer the possibility to conclude a contract quickly, conveniently and in 100% remotely.

To entrust us as your company's authorised representative in Germany:

  1. Select the type of products you sell to customers in Germany and proceed to the form.

[here I would give butons with links Batteries and accumulators, Electrical and electronic equipment, Packaging].

  1. Complete the quantities and weights of the products to be introduced.
  2. Enter your company details and confirm that they are correct.
  3. Confirm your order and follow the instructions you will receive from us by email.

Not sure if the EPR regulations apply to your company too? Get a free consultation with our experts! Go to the calendar and book your appointment.

What are our responsibilities as an authorised representative in Germany?

Interzero has been providing expert environmental services to clients in every industry for more than 30 years. We are present in 10 countries, including Germany, where we take over the extended producer responsibility obligations from businesses.

As an authorised representative of your company in Germany, we will take care of:

  • registration of your company in the relevant registers (LUCID, EAR),
  • recycling and management of waste from packaging, equipment and batteries that you place on the German market,
  • accession to the extended producer responsibility scheme,
  • reporting on packaging, equipment and batteries introduced in each calendar year,
  • packaging licensing and paying licence fees (if required) on behalf of your company,
  • representation of your company with German authorities and bodies.

Our experts will familiarise themselves with the specifics of your business in order to precisely define your responsibilities as a producer in the German EPR system. This will enable us to carry out all tasks efficiently, comprehensively and for the benefit of the environment.

FAQ

Find out the answers to the most common questions about the service of an authorised EPR representative in Germany.

EPR (eng. Extended Producer Responsibility) is the extended producer responsibility, i.e. the concept that the producer should take responsibility for the entire life cycle of the products he produces - from design to production to the management of the resulting waste. Under EU directives, all EU Member States have been obliged to introduce into their legal orders provisions establishing extended producer responsibility with regard to:

  • packaging and packaged products,
  • electrical and electronic equipment (EEE),
  • batteries and accumulators.

The establishment of an authorised representative for the EPR follows from the provisions of 2 German acts: the Electrical and Electronic Equipment Act (ElektroG) and the Battery Act (BattG).

Although the Extended Producer Responsibility schemes in the various EU Member States have been constructed on the basis of the same EU directives, their design and operation differ significantly. Not only does each member state organise collection differently, but local legislation is not always translated into other languages, making it difficult for foreign businesses to follow and understand the EPR system in place in their country.

To gain confidence that foreign companies will strictly comply with EPR regulations, each Member State may oblige them to appoint an authorised representative - a local entity that will guarantee the fulfilment of all the manufacturer's obligations.

At this point in the German EPR system, such an obligation only exists for batteries, accumulators and electrical and electronic equipment. The obligation to establish an authorised representative for packaging and packaged products will come into force in 2026, when the EPR will become applicable in all Member States.

An authorised representative for EPR can be a natural or legal person who satisfies all of the following conditions:

  • has a residential address or established in Germany,
  • obtained entry in the relevant register (LUCID for packaging, EAR for electrical and electronic equipment and for batteries and accumulators),
  • has entered into an agreement (in writing) with a foreign manufacturer transferring obligations under the EPR.

The manufacturer, which plans to sell to German customers batteries and accumulators and electrical and electronic equipment should appoint an authorised representative for the EPR even before the start of operations. The role of the authorised representative will then be to take steps to enable the products to be legally marketed, including obtaining the necessary registrations on behalf of the manufacturer, providing warranties and joining the extended producer responsibility (PRO) scheme.

Traders placing packaging and packaged products on the German market may appoint an authorised representative at any time, either before or during the course of business. However, it must be borne in mind that from August 2026 it will be mandatory to have an authorised representative for packaging for all manufacturers placing packaging and packaged products on the German market.

Yes. We currently provide the services of an authorised representative of on 30 markets - in all 27 EU member states, plus the UK, Norway and Switzerland. This allows entrepreneurs introducing packaging and products regulated by the EPR into multiple countries to quickly, conveniently and comprehensively establish an authorised representative in the various European markets.

Do you operate in several European countries?

  • Explore EPR services for manufacturers introducing equipment and batteries!
  • Check out the offer for EPR services for the introduction of packaging and packaged products!

Need support with EPR duties in other countries?

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Contact

email

epr@interzero.pl