5 min article

Extended Producer Responsibility selling in Germany

Extended Producer Responsibility (EPR) is a broad collection of international regulations around waste management. When you offer to sell certain products to buyers in Germany, you must comply with EPR rules around environmental legislation, which may include rules for items, components and packaging.

As a global marketplace, eBay has an obligation to ensure that our sellers are compliant with certain EPR regulations, including the German Packaging Act and the German Electrical and Electronic Equipment (EEE) Act. For more information about these regulations, and to help you understand your responsibilities as a seller, see our sections below. Sellers who don’t comply with these regulations may have their listings hidden.

The German Packaging Act

If you're a business seller with buyers based in Germany, you need to make sure you’re compliant with the German Packaging Act. This means you need to buy a licence for your packaging and make sure the details are registered. This applies to all business sellers with buyers based in Germany, whether you package and ship items yourself, or import prepackaged goods into Germany.

To help you with the process, you can purchase a licence for your packaging from our partner, Lizenzero. For more information, visit the Lizenzero - eBay page - opens in new window or tab.

Additionally, you must register your details with the Central Agency Packaging Register Authority (ZSVR) to receive your individual LUCID ID number. For more information on what you need to do to register and report your data, visit the ZSVR - opens in new window or tab page, where you’ll also find information on additional system operators.

Finally, submit your LUCID ID number to eBay using the steps below.

Submitting your LUCID ID number to eBay

Once you’ve received your LUCID ID number you should submit it to eBay. Here’s how:

  1. Go to the Account - opens in new window or tab section of My eBay.
  2. Go to Personal information and privacy and select Business information. You may be prompted to log in again.
  3. Go to the Business details section and select Add next to LUCID ID.
  4. Enter your LUCID ID number and select Save.

Once you’ve submitted your Lucid ID you are ready to list your items. Make sure that all of your items are listed in the correct category to help ensure you’re fully compliant with the Packaging Act.

Packaging covered by the German Packaging Act

The German Packaging Act covers all packaging that ultimately ends up with German end consumers, as it will need to be disposed of by them. It doesn't matter what material the packaging is made of, because all packaging has to be licensed, including cardboard, plastic, and glass. Packaging includes:

  • Product packaging
  • Shipment packaging, including filling and cushioning materials
  • Service packaging, for example, carrier bags or single-use coffee cups

Tip
More information on what the German Packaging Act means for you can be found in our Seller Center - opens in new window or tab.

The German EEE Act (ElektroG)

If you're a seller within the scope of the German EEE Act (ElektroG) offering to sell certain electrical goods or electronic equipment - opens in new window or tab to consumers based in Germany, you need to make sure you're compliant with the law. This means obtaining a WEEE number, submitting the WEEE number to eBay, and providing recycling information to your buyers.

Different types of sellers will need to take different actions to be compliant.

Domestic business sellers

  • If you're a brand-owner (manufacturer or producer), you must register your brand with EAR - opens in new window or tab in the correct categories to receive a WEEE number
  • If you’re a German seller importing electronic items to Germany, you must check with EAR - opens in new window or tab to see if the product or brand you’re selling has already been introduced to the German market and registered in the right EAR categories. If not, you should register this product with EAR to obtain a WEEE number
  • If you're a domestic reseller, you must check with EAR - opens in new window or tab to see if the product or brand has already been correctly registered by the manufacturer. If not, you should register this product with EAR to obtain a WEEE number

International business sellers

German EEE Act (ElectroG) categories

The categories of electrical goods in scope include:

  • Temperature exchange equipment
  • Screens, monitors and equipment containing screens having a surface greater than 100 cm²
  • Lamps
  • Equipment with any external dimension more than 50 cm
  • Equipment with no external dimension more than 50 cm
  • Small IT and telecommunication equipment with no external dimension more than 50 cm

For more information on what each category includes, see the EAR ElectroG categories - opens in new window or tab page.

Finally, to sell these items on eBay, you must submit your WEEE number to eBay.

Submitting your WEEE number to eBay

Once you’ve received your WEEE number, you should submit it to eBay. Here’s how:

  1. Go to the Account section of My eBay.
  2. Select Business info.
  3. Go to WEEE ID and select Add.
  4. Enter your WEEE number and select Save.

Selling used goods

If you're selling used electrical goods or electronic equipment, you may still need a WEEE number:

  • If you're importing used electrical goods or electronic equipment for sale in Germany for the first time, then you will need a WEEE number to sell on eBay
  • If you're selling used electrical goods or electronic equipment that is already in Germany and is not for sale under your own brand name, then you don't need a WEEE number to sell on eBay

Tip
If you’re unsure if you need a WEEE number, see the EAR - opens in new window or tab website for more information.

Providing recycling information

If you're a producer, importer, or business seller with buyers based in Germany, you also have an obligation to include some written information about recycling the electrical goods or electronic equipment you're selling.

You must include the following written information when you send items to your buyer:

  • how waste equipment can be collected separately for recycling
  • how to remove old batteries, accumulators and lamps from waste equipment before returning it, if this can be done without destroying the waste equipment, and the waste equipment is not intended for reuse
  • the distributor's and the producer's returns and take-back policies
  • information on deleting personal data from waste equipment before recycling
  • the meaning of the wheelie bin symbol on waste equipment

Additionally, the crossed-out wheelie bin symbol must be permanently attached to the items, or, in exceptional cases, printed on the packaging, the user instructions, or the guarantee certificate. Also, all electrical goods and electronic equipment must be permanently labelled with the producer's information.

EPR regulations in Austria

EPR regulations have also been revised in Austria and include new obligations for the sale of batteries and electrical items, as well as packaging waste. Business sellers have to register with a recycling system if they put these products into circulation in Austria. Sellers who are not located in Austria need an EU-authorised representative for the registration. For further information, please visit our partner Lizenzero's website - opens in new window or tab.

Helpful links

For more information about how the German EEE Act (ElektroG) may affect your selling on eBay, see the helpful links below:

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