This responsibility covers packaging, electrical and electronic equipment and batteries. The obligations and procedures differ between Germany and Austria.
We support companies in complying with their legal obligations, taking care of the administrative management of their files so they can focus on their core business.
Contact us at environnement@francoallemand.com to discuss your project or specific requirements. Our team of experts will develop a customised solution for you.
You can also request a quotation tailored to your needs here:
Reporting in Germany
Household packaging
Who is responsible?
- If you sell directly to German households then you are required to register.
- If you sell through German retailers, either you or your retailer must register.
- If neither you nor your distributor take over this responsibility, the responsibility falls, by law, on the first party that places the packaged products on the market.
The “first party that places the packaged products on the market” is usually the company that is legally responsible for the packaged goods when they cross the border (except in the case of private labels). You should therefore consult your German retailer to avoid double reporting.
Which products are concerned?
- Household and service packaging is concerned, such as product packaging and samples, as well as outer and transport packaging, for which the end users are German households and “comparable sources of waste generation” (e.g. restaurants, hotels, hospitals and agricultural businesses).
- Transport packaging is not subject to the reporting obligation under the dual system and must instead be reported to the Foundation Central Agency Packaging Register (ZSVR).
Pfand (deposit)
Who is responsible?
- As a manufacturer, importer or initial distributor of single-use beverage packaging, you are subject to the deposit legislation for single-use beverage packaging.
Which products are concerned?
- Single-use beverage packaging for private end consumers, plastic bottles and cans with a capacity of 0.1 to 3 litres are concerned.
Waste electrical and electronic equipment
Who is responsible?
- If you are a manufacturer or distributor of electrical and electronic equipment (WEEE), you must register with the Waste Register for Batteries and Accumulators – stiftung elektro-altgeräte register (EAR) before selling your products in Germany.
- If you are a manufacturer or distributor without a German branch, you must appoint an authorised representative to fulfil your obligations and comply with the German Electrical and Electronic Equipment Act.
Which products are concerned?
- The classification of electrical and electronic equipment is prescribed by law. There are 9 types of household devices and 8 types of commercial devices.
Portable batteries and accumulators
Who is responsible?
- If you place batteries or products containing batteries on the German market for commercial purposes or if you distribute batteries that have not been registered by the manufacturer, you must register with the Waste Register for Batteries and Accumulators – stiftung elektro-altgeräte register (EAR) before doing so.
Which products are concerned?
- This applies to portable batteries and accumulators, such as button cells and alkaline batteries. However, this also includes lead accumulators.
Reporting in Austria
Household packaging
Who is responsible?
- If you sell directly to Austrian households, you must register your packaging with an Austrian compliance scheme.
- If you export your products to Austria via an Austrian distributor, it is the responsibility of your Austrian importer to register your packaging with an Austrian compliance scheme.
- However, a foreign company can agree with its Austrian distributor for the latter to join a take-back system on its behalf. Foreign companies without a registered office in Austria must appoint an authorised representative in Austria.
Which products are concerned?
- All sales, collection and transport packaging must be reported to a take-back system.
- In addition, packaging is divided into 47 product groups according to its contents. A percentage is set for each group reflecting the proportion of products used in households and industry.
Single-use plastic products
Who is responsible?
- Do you export single-use plastic products to Austria? If so, either the producer or the Austrian importer must register the packaging with an Austrian compliance scheme.
- However, a foreign manufacturer can agree with their Austrian distributor or importer to join a compliance scheme on their behalf.
- Foreign companies without a branch in Austria must appoint an authorised representative based in Austria to comply with this regulation.
Which products are concerned?
- Products that are consumed directly on site or on the go, such as small bags and packaging made of flexible plastic film, beverage containers, wet wipes, balloons, tobacco products and fishing equipment, as well as very light plastic bags.