Since Amazon made WEEE registration mandatory in Germany in 2021, sellers of electrical and electronic products must obtain a WEEE number and submit it to the platform for verification.
[Image: Email from a platform requiring WEEE registration]
[Image: WEEE registration number successfully validated on a platform]
[Image: WEEE category selection interface]
Subsequently, other major cross-border e-commerce platforms—including but not limited to AliExpress, Alibaba, TEMU, and eBay—have also required sellers to register for and verify their WEEE numbers.
[Image: TEMU’s WEEE submission page]
When selling electronic products, have you received a request from a platform to submit your WEEE registration number?
Don’t stop here! This related post dives deeper into what matters most.
Understanding WEEE Compliance
WEEE stands for Waste Electrical and Electronic Equipment. The directive governs the recycling of waste that is generated when consumers discard electronic products at the end of their life cycle. The first EU WEEE Directive (2002/96/EC) took effect in February 2003, mandating the treatment, recovery, and recycling of electrical and electronic equipment. An updated version, WEEE 2.0 (Directive 2012/19/EU), came into force on February 14, 2014.
Currently, the WEEE Directive is classified under the broader EU Extended Producer Responsibility (EPR) framework. EPR regulations encompass all environmental directives, such as WEEE registration, the Packaging Act, and the Battery Act. France, for example, has 18 distinct EPR registration directives.
WEEE compliance aims to encourage the design of electronic products with environmentally safe recovery and recycling in mind. It works in tandem with RoHS (Restriction of Hazardous Substances) compliance. The key difference is that RoHS is a product certification that regulates hazardous substances used in manufacturing EEE, while WEEE is a producer registration that regulates the disposal and recycling of that equipment. All EEE sold on the EU market must be WEEE compliant and bear the “crossed-out wheelie bin” symbol. Therefore, EEE manufacturers must comply with both.
Many sellers encounter conflicting information and various problems during the registration process, especially on Amazon, where registering with the wrong brand or category can lead to failed verification and negatively impact store sales. This article provides a detailed guide to avoiding these common pitfalls.
Pitfall #1: The WEEE Directive Does Not Require a WEEE Report
Some sellers, particularly those with manufacturing backgrounds, may still believe that WEEE compliance requires both a WEEE test report and a registration certificate. In fact, the sole requirement is WEEE registration. Platforms verify the registration number issued by the official national registry. In Germany, this number is in the format DE + 8 digits, and the official registration body is Stiftung EAR. Only numbers registered with Stiftung EAR are considered compliant.
In each EU country, companies considered “producers” have the following WEEE obligations:
- Register with the appropriate national authorities to ensure compliance with waste management regulations.
- Regularly declare the quantity and weight of electronic products placed on the market.
- Provide end-users with information and instructions regarding electronics recycling.
Pitfall #2: WEEE Registration Cannot Be Expedited
The turnaround time for WEEE registration is a common concern and can be affected by many factors. Based on years of experience, the following issues can cause delays:
- Incomplete or Incorrect Application Materials: When submitting an application, we cross-reference the seller’s information with their platform storefront details. Delays can occur if a seller has recently changed their business license information, updated their storefront details during the registration process, or if the products they sell differ significantly from their application. For non-German companies (e.g., based in Hong Kong), providing incorrect or incomplete business licenses is another common issue.
- Stricter Requirements for German-Based Companies: Stiftung EAR has rigorous verification procedures for local German companies, including checks on the legal representative, phone number, and email address.
- Power of Attorney Issues: Incorrect or illegible signatures or seals on the power of attorney can also delay the process.
- Audits of Authorized Representatives: Stiftung EAR conducts annual audits of authorized representatives. If an application is submitted during an audit period, all WEEE services may be suspended until the audit is complete.
- Registration Quotas (New in 2024): Starting in 2024, EAR requires authorized representatives to apply for a registration quota. If a representative has not secured their quota in time, it will affect processing times.
The normal timeframe for WEEE registration is 4–8 weeks. In the past, the official timeline has been as long as 8–12 weeks, while the currently posted estimate is 6–7 weeks. Actual times can vary; receiving a number in one month or two months are both within the normal range. However, the process cannot be rushed. The authorities do not offer an expedited service, nor do they respond to informal requests to speed up the process. All applications are submitted to Stiftung EAR’s system and randomly assigned to reviewers. While individual reviewers may differ in their processing speed and level of scrutiny, the timeline will generally fall within the official range. Be wary of any agent who claims they can expedite your WEEE registration; this is almost certainly false.
Pitfall #3: Your WEEE Brand and Category Must Match Those on the Platform
To issue a registration number, authorities require that it be associated with at least one brand(such as CNCOB). Critically, this brand must be identical to the one used on your Amazon store. Brand registry on the platform is mandatory. Even if you obtain a WEEE number, it will fail verification if your store is not brand-registered or is found to be misusing a brand.
The product category must also align with the platform’s determination, especially for ambiguous products. While official guidelines might suggest a product belongs in Category 5, if Amazon classifies it as Category 6, you must follow Amazon’s classification. You can confirm the correct category after listing a product by visiting the WEEE submission page:
Navigate to the category selection field. The correct category is whichever one the system permits you to select for your product.
If your product has been misclassified (for example, it is not an electronic item but Amazon is still requiring a WEEE number), you can contact customer service to file an appeal. Alternatively, you can send an email to: epr-de-weee-appeals-cn@amazon.com.
WEEE Product Categories
- Category 1. Temperature Exchange Equipment (TEE): All EEE that use refrigerants (substances other than water) for heating and cooling. Examples include refrigerators, air conditioners, and heat pumps.
- Category 2. Screens, Monitors, and Equipment with Screens > 100 cm²: Devices whose primary purpose is to display information. Examples include monitors, televisions, laptops, tablets, and e-readers. This excludes smartphones (screen is too small) and smart refrigerators (primary purpose is cooling).
- Category 3. Lamps: Includes fluorescent, LED, high-intensity discharge (HID), and low-pressure sodium (LPS) lamps and tubes. It does not include luminaires or light fixtures, which fall under Categories 4 or 5.
- Category 4. Large Equipment: Any EEE not in Categories 1, 2, or 3 with at least one external dimension greater than 50 cm. Examples include washing machines, dryers, electric stoves, large medical devices, photovoltaic panels, and large luminaires.
- Category 5. Small Equipment: Any EEE not in other categories with all external dimensions less than 50 cm, provided it is not IT equipment. Examples include vacuum cleaners, microwaves, small kitchen appliances, and consumer electronics.
- Category 6. Small IT and Telecommunication Equipment: Any EEE used for IT or communication with all external dimensions less than 50 cm. Examples include smartphones, desktop computers, GPS devices, printers, routers, and fax machines.
Pitfall #4: Your WEEE Number Can Be Used on Multiple Platforms
WEEE registration is tied to the producer’s company name, brand, and product category. If you use the same company, sell the same brand, and list the same product category on multiple platforms, you can use the same WEEE number across all of them. For instance, if Company X sells Brand A products on both Amazon and TEMU, the same WEEE number will be successfully verified on both platforms.
Pitfall #5: The Wheelie Bin Symbol Can Be Used Before WEEE Registration
According to the Electrical and Electronic Equipment Act, manufacturers are responsible for the entire lifecycle of the equipment they place on the market. This includes both registration and labeling obligations. Manufacturers must affix the “crossed-out wheelie bin” symbol on their products and packaging.
In practice, sellers can source products that already bear the symbol or request that their factory apply it before shipment. The labeling and registration obligations are separate. You can apply the wheelie bin symbol to your products before your WEEE registration is complete, and you can register products that do not yet bear the symbol. However, for all final products and packaging exported to the EU, compliance labeling is mandatory. Both the wheelie bin symbol and the CE mark are required for exporting to the EU.
The EU WEEE Directive is implemented via national regulations in all European Economic Area (EEA) countries (all EU member states plus Norway, Liechtenstein, and Iceland). WEEE must be registered separately in each country. In addition to Germany, countries like France, the UK, Spain, Italy, and Austria have integrated WEEE registration into their manufacturer compliance obligations. WEEE registration requirements will be gradually rolled out in more countries in the future.
Therefore, whether you sell online or offline, it’s crucial to plan ahead and register for WEEE in advance to avoid any disruption to your sales.
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