Germany's WEEE Rules: Amazon Requires Registration Numbers for Electrical Goods

In brief: under Germany's electrical waste law, whoever puts electrical and electronic equipment (EEE) on the German market must be registered with Stiftung EAR and hold a WEEE-Reg.-Nr. for each brand and device type. Amazon told sellers in July 2022 that it would have to suspend non-compliant listings from 1 January 2023; in December 2022 that date moved to 1 July 2023. Registration could take over ten weeks, and Amazon warned it might start deactivating listings from 5 June 2023, with affected products also losing Pan-European FBA until fixed.

Amazon WEEE Germany timeline

Date	What happened
11 July 2022	Amazon announced WEEE checks for Germany, due from 1 January 2023
October 2022	Compliance portal opened for submitting WEEE-Reg.-Nrs.
21 December 2022	Enforcement pushed back to 1 July 2023
5 June 2023	Early deactivations possible, as validation took about four weeks
1 July 2023	Non-compliant electrical listings deactivated

Who had to register

Stiftung EAR's rules decide whether you count as the producer. If you do, you need your own registration; a producer based abroad registers through an authorised representative, who must be on Stiftung EAR's approved list. If you're not the producer, every brand and device type you list must already be registered by its producer — otherwise you register as producer yourself or ask your supplier to. Amazon validated every number against the Stiftung EAR register.

A worked example

An overseas seller of phone chargers under its own brand sells €8,000 a month on Amazon.de. Without an authorised representative and a WEEE-Reg.-Nr. by July 2023, those listings were switched off, the chargers lost Pan-European FBA, and roughly €8,000 a month of German sales stopped until a valid number was provided.

What it means for your bookkeeping

• Registration isn't free. Authorised representative fees, registration charges and take-back scheme costs are paid to third parties. Post them as overheads of selling in Germany, supported by invoices.

• Watch for stranded stock. Deactivated listings leave stock unsold in German warehouses. If it has to be removed or disposed of, that shows up as fees in your settlements and may need a stock write-down.

• Revenue drops can be compliance, not demand. A sharp fall in Amazon.de electrical sales around mid-2023 may trace back to deactivated listings.

• VAT on third-party fees: follow each provider's invoice.

• Keep it out of selling fees. Representative and scheme costs are third-party bills — see Amazon FBA bookkeeping and reconciling an Amazon settlement.

How TrueBooks helps

TrueBooks shows profit by marketplace in each marketplace's own currency, and posts removal and disposal fees from your settlements to Xero, so the cost of a compliance gap is visible. It doesn't handle EPR registrations. See the Amazon Xero integration.