EPR · WEEE & batteries
WEEE and battery registration for online sellers
Packaging EPR catches everyone who ships a parcel. Electronics EPR catches more sellers than expect it, because the scope has been open since 2018: if a product runs on mains power or a battery, from a kettle to a light-up sneaker, it is electrical and electronic equipment. Selling it into an EU country makes you a producer in that country, and you have to be registered in its national register before the first unit ships, not after. Batteries are a third, separate registration on top, and Germany reset its battery regime in January 2026 in a way that quietly invalidated registrations sellers thought they still had.
You are the producer, even if you did not make it
The WEEE Directive (2012/19/EU) puts the obligation on whoever first places equipment on a member state's market. Selling cross-border direct to consumers in a country makes you that person there, even if you bought the product from a manufacturer in Shenzhen and never touched an EU warehouse. Your supplier's compliance in their own market does nothing for you in yours.
What counts as electrical and electronic equipment
More than people assume. Since August 2018 the directive has run on open scope, meaning anything dependent on electric currents or electromagnetic fields to work is in unless it is specifically excluded. The six collection categories are:
- Temperature exchange equipment (fridges, air conditioners, heat pumps)
- Screens and monitors with a surface greater than 100 cm2
- Lamps
- Large equipment, any external dimension over 50 cm
- Small equipment, all dimensions 50 cm or under
- Small IT and telecommunications equipment, all dimensions 50 cm or under
The unexpected ones
Illuminated furniture, greeting cards that play a tune, heated clothing, cordless tools, vape devices, toys with a chip, and anything with an LED in it are all in scope. If it needs a battery or a plug to do the thing it is sold to do, assume it is EEE until you have checked otherwise.
Where you register
There is no single EU electronics register, exactly as with packaging. You register in each country you sell into, and each has its own authority, its own number, and its own reporting cadence.
| Country | Register | What you end up holding |
|---|---|---|
| Germany | stiftung elektro-altgeräte register (stiftung ear), under ElektroG | A WEEE-Reg.-Nr. DE, plus a take-back scheme contract and, for B2C, an annual financial guarantee |
| France | SYDEREP, operated by ADEME | An identifiant unique (IDU), plus membership of an eco-organisme such as ecosystem or Ecologic |
| Spain | RII-AEE, the integrated industrial register | A producer registration number and membership of a collective system |
| Italy | Registro AEE, run through the chambers of commerce | A registration number and consortium membership |
| Netherlands | Nationaal (W)EEE Register | A registration, with Stichting OPEN as the producer organisation |
Germany's financial guarantee is the one that surprises people. If you sell equipment that can end up in a private household, ElektroG requires you to prove in advance that the future disposal of those units is funded, renewed annually, and the cost commonly lands in the low hundreds of euros for a small seller. It is a genuine cash requirement, not a form.
The authorised representative rule
A producer with no establishment in the country cannot register directly. Germany's ElektroG requires cross-border distance sellers to appoint a Germany-established authorised representative, and a manufacturer outside the EU has to have one in place before registration with stiftung ear is possible at all. The same pattern repeats in the other markets. Practically, this means the appointment is not the last step in your compliance project. It is the first, because nothing else can start without it.
Marketplaces and fulfilment partners now check
Germany obliges online marketplaces and fulfilment service providers to verify that a seller is registered before letting them sell or handling their stock. This is why the registration number matters commercially long before any authority contacts you: the first consequence of not having one is usually a listing removed or a warehouse refusing goods.
Non-compliance with ElektroG can attract fines up to €100,000, alongside confiscation of profits made from non-compliant sales and effective exclusion from German marketplaces. For a seller running on marketplace revenue, the exclusion is worse than the fine.
Batteries are a separate registration, and Germany reset it
Batteries have their own EPR stream under Regulation (EU) 2023/1542, and whoever first makes a battery available on a member state's market, including a distance seller, carries the obligations. Since 18 August 2025 producers have also had to adopt and publish a due diligence policy covering their battery supply chain.
Germany rewrote its national implementation. The BattDG replaced the old Battery Act (BattG) in October 2025, and this is the part sellers missed: registrations held under the old BattG were only valid until 15 January 2026. Producers who did not transfer to the new system and prove membership of a producer responsibility organisation are treated as having had their registration revoked retroactively from 1 January 2026, which triggers an immediate sales ban that extends down the chain to distributors and fulfilment providers. Foreign producers have needed a Germany-established authorised representative for batteries since 18 August 2025.
Worth checking today
If you registered batteries in Germany before 2026 and have not touched the paperwork since, check the status of that registration now. A retroactive revocation is not something you find out about gracefully; you find out when a marketplace or a fulfilment partner stops your listings.
Further out, from 18 February 2027, electric vehicle and industrial batteries above 2 kWh placed on the EU market need a digital battery passport accessible by QR code. That is not most Shopify sellers, but it is the direction of travel for product-level digital records.
Ordering the work so it does not stall
Electronics compliance fails in a predictable place: people start with the register, discover they cannot register without a representative, and lose a month. Do it in this order.
- Decide which of your SKUs are EEE, and which contain or come with batteries
- Pick the countries you actually ship them to
- Appoint an authorised representative in each of those countries first
- Register in the national WEEE register and get your number on file
- Register batteries separately, and check any pre-2026 German registration is still valid
- Contract a take-back or collection scheme, and fund the German financial guarantee if you sell B2C there
- Give your registration numbers to every marketplace and fulfilment partner before they ask
- Do not forget packaging EPR, which applies to the same parcels in parallel
How Assuro helps
Assuro reads your Shopify catalogue, flags which products look like electrical equipment or battery-bearing goods, shows the countries you ship them into, and tracks which registrations and deadlines you have on record against them. It organizes and flags. It does not act as your authorised representative, register you with stiftung ear or any other authority, join schemes, or file reports.
Frequently asked questions
Do I need WEEE registration if I sell only a handful of electronic items?
Yes. WEEE obligations do not have a volume threshold in the main markets. Placing a single unit of in-scope equipment on a country's market makes you a producer there, and registration is meant to happen before the first sale.
Is a product with a small LED really in scope?
Usually yes. The directive has run on open scope since August 2018, so equipment that depends on electric current to perform its function is in unless it falls under a specific exclusion. Light-up shoes, musical greeting cards and illuminated furniture are all standard examples.
Do I need a separate registration for the batteries inside my product?
Yes. Batteries are a distinct EPR stream with their own registration, reporting and take-back obligations, whether the battery is loose, included in the box, or built into the product.
What happened to German battery registrations in January 2026?
Germany replaced the BattG with the BattDG in October 2025. Registrations under the old law were valid only until 15 January 2026. Producers who did not transfer and prove membership of a producer responsibility organisation are treated as revoked retroactively from 1 January 2026, with a sales ban that also binds distributors and fulfilment providers.
Does Assuro handle WEEE registration for me?
No. Assuro organizes and flags. It identifies which products look like electrical equipment or contain batteries, shows where you sell them, and tracks what registrations you hold. Appointing representatives, registering, and reporting stay with you.
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