The direct answer
A service contract is not automatically a statutory appointment. Define for each stream who provides support and who assumes legal obligations in their own name.
What to check
ElektroG: valid appointment and confirmation
ear describes a written German-language appointment and confirmation of nomination. A German-established producer can instead authorise a service provider to assist. stiftung ear · authorised representative and power of attorney
Battery law: a separate process
ear requires a German representative for foreign battery producers without a German establishment. Each producer can have only one for all brands and categories. stiftung ear · battery registration application
Packaging: a personal registration duty
ZSVR specifies representation for foreign direct sellers without a German branch. LUCID registration and master-data changes remain the producer’s personal duties. ZSVR · authorised representatives
OfH is not general data support
OfH needs approval for its battery responsibilities. A general service agreement replaces neither that approval nor confirmed participation. stiftung ear · approval of battery OfHs
Guarantee is an additional task
An insolvency-proof WEEE guarantee funds waste-equipment disposal when called. A representative can coordinate compliance; the required cover needs separate evidence. stiftung ear · insolvency-proof guarantee
| Role | What to clarify | Relevant evidence |
|---|---|---|
| Coordination provider | Data preparation, tasks and service scope. | Service agreement and any power of attorney. |
| Statutory authorised representative | Producer, product stream and assumed obligations. | Appointment and required registry steps. |
| Battery OfH | Approval, category and confirmed participation. | Scheme agreement and participation confirmation. |
| WEEE guarantee service | Equipment type, calendar year and cover. | Appropriate guarantee evidence. |
stiftung ear · authorised representative and power of attorney · stiftung ear · approval of battery OfHs · stiftung ear · insolvency-proof guarantee
Your action plan
The following steps are our suggested way to organise your project.
- List products, countries and responsible entities before appointing a provider.
- Separate the service contract from statutory appointment, scheme participation and guarantee records.
- Define who supplies data, who reviews it and who submits applications or reports.
- Review termination and provider changes alongside the affected registrations.
- Obtain evidence for each role rather than retaining only one consolidated invoice.
Prepare your records
Locations and company details of the entities involved, product streams, existing numbers, responsibility matrix, contract periods and representation, scheme and guarantee evidence.
Frequently asked questions
Is portal access a statutory appointment?
No. A login does not establish a valid statutory appointment. Check the agreement and required process for the product stream.
Does a WEEE appointment also cover batteries?
ear treats the two appointments independently. Check the battery appointment and its required declarations separately.
Can one provider coordinate all tasks?
Yes, a central contact can coordinate the process. Legal roles, scheme services and guarantees still need clear individual allocation.
What role does SINNO take?
The agreed project scope defines the tasks. SINNO supports you from Germany and coordinates suitable external services; an enquiry alone does not create a statutory appointment.
Sources and scope
- stiftung ear · authorised representative and power of attorney
- stiftung ear · battery registration application
- ZSVR · authorised representatives
- stiftung ear · approval of battery OfHs
- stiftung ear · insolvency-proof guarantee
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.