The direct answer
Start with producer status and the combination of brand and equipment type. A user account or submitted application is not registration approval.
What to check
Account versus approval
ear requires a registration application for each brand and equipment type. The relevant devices may be placed on the market only after registration approval. stiftung ear · WEEE registration application
Foreign producers
Foreign producers without a German establishment cannot register themselves. ear describes appointment of a German authorised representative and confirmation of that appointment. stiftung ear · foreign WEEE producers
B2C: secure disposal funding
Devices usable by private households require insolvency-proof guarantee evidence at registration and annually. This secures waste disposal and is not a product warranty. stiftung ear · insolvency-proof guarantee
B2B: organise an actual return route
For B2B equipment, ear requires a take-back concept: how the end user returns waste equipment and how treatment is arranged. Identify any appointed third parties. stiftung ear · B2B take-back concept
| Question | Assessment | Next evidence |
|---|---|---|
| Can the device be used by a private household? | Assess B2C classification, including business sales. | Correct equipment type and guarantee evidence. |
| Is private use excluded? | Substantiate the B2B classification. | Evidence of use and a take-back concept. |
| Is classification still unclear? | Review the technical description and use. | Resolve classification before finalising the application. |
Your action plan
The following steps are our suggested way to organise your project.
- Record all relevant SKUs with photos, technical descriptions, brands and intended use.
- Map each SKU to a brand and equipment type. Check new combinations rather than reusing a number without review.
- Identify the applicant and arrange statutory representation where required.
- Plan guarantee or B2B evidence and operational take-back as separate work packages.
- After approval, check the authorised brands and equipment types; include the number and evidence in your internal release record.
Prepare your records
Company data, brand list, SKU descriptions, equipment weights, use descriptions, any representation documents, and guarantee or B2B take-back evidence. Separate existing registrations from new application combinations.
Frequently asked questions
Does every SKU need its own registration?
Registration is by brand and equipment type, not individual SKU. Use a SKU mapping to check portfolio coverage.
Are business sales automatically B2B?
No. Classification concerns how the equipment can be used. A business invoice alone does not prove private use is excluded.
Is the insolvency-proof guarantee a product warranty?
No. It secures waste-equipment disposal funding if the guarantee is called. Product warranty is a different matter.
Can SINNO help without its own guarantee scheme?
Yes. SINNO can coordinate data, application steps and suitable external guarantee services. Provider and contractual scope are clarified before delivery.
Sources and scope
- stiftung ear · WEEE registration application
- stiftung ear · foreign WEEE producers
- stiftung ear · insolvency-proof guarantee
- stiftung ear · B2B take-back concept
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.