EPR in Germany: WEEE, batteries and packaging

The direct answer

Packaging registration does not cover electrical equipment or batteries. Classify each product and its packaging separately.

What to check

Electrical equipment: ear

Check producer status, equipment type and registration before selling. ear explains separate registration, reporting and take-back obligations. stiftung ear · producer obligations

Batteries: an approved OfH

ear specified 15 January 2026 as the participation deadline. Check current registration validity and participation in an approved OfH. stiftung ear · approved battery OfHs

Packaging: LUCID

PPWR producers must register in LUCID. Also check packaging type, scheme participation and master data; foreign direct sellers to end users need representation. ZSVR · LUCID registration

Online platforms: two packaging records

ZSVR describes checking LUCID registration confirmation and a self-certification of fulfilled EPR obligations. Missing or inconsistent evidence can prevent an offer. A register entry alone does not replace that check. ZSVR · Onlinehandel und Nachweise

An EU establishment is not a German establishment

For foreign EEE producers without an establishment in Germany, stiftung ear explains the appointment of a German-established authorised representative and confirmation by ear. Check the specific producer role; an EU address alone does not settle German registration. stiftung ear · foreign WEEE producers

Working checklist for entering Germany
Check	Records to prepare
Identity and sales route	Legal entity, establishment, brands and supply chain; check the role for each stream.
Electrical equipment	Existing registration and matching brands/equipment types; confirmed appointment where required.
Packaging	Current LUCID data and EPR self-certification; keep scheme evidence separately.
Ongoing work	Document quantity sources, periods, contract scope and responsibilities.

ZSVR · Onlinehandel und Nachweise · stiftung ear · foreign WEEE producers

Your action plan

The following steps are our suggested way to organise your project.

List each SKU as electrical equipment, battery and packaging materials.
Assign an owner and an evidence folder to each stream.
Reconcile registry data, contracting entities and marketplace details.
Schedule recurring volume reconciliation and contract review.

Prepare your records

SKU list, brands, equipment categories, battery data, packaging weights and existing registration evidence.

Frequently asked questions

Is LUCID a WEEE number?

No. Packaging and electrical equipment registration are separate processes.

Does SINNO operate its own OfH?

No. SINNO can coordinate work with external approved providers.

Sources and scope

This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.

SINNO GmbH is your contact in Germany. We can consolidate tasks and coordinate suitable external providers. Local representation, approved schemes and any required guarantees are agreed separately for each project.