Update for German Electrical and Electronic Equipment Act Comes into Force in 2026
In November 2025, the German parliament (Bundestag) passed the third amendment to the Electrical and Electronic Equipment Act (ElektroG4). After final approval by the Federal Council (Bundesrat), the law is scheduled to come into effect on January 1, 2026. With a collection rate of only 38.6%, Germany is far behind the EU target of 65%. The new amendment aims to close this gap and minimize fire risks caused by lithium batteries.
Most Important Changes for Manufacturers and Retailers
Extended Take-Back Obligations (from July 1, 2026)
- Retailers of single-use e‑cigarettes must take back used products free of charge at all points of sale—regardless of a new purchase.
- The take-back obligation also applies to online retail (distance selling).
Background: Built-in lithium batteries are often disposed of incorrectly and cause fires in garbage trucks and waste facilities.
New Labelling Requirements (from July 1, 2026)
- Collection and take-back points must be uniformly marked with a new, colored symbol (replacing the previous black-and-white symbol).
- Retailers must display the symbol prominently at the entrance of a store (at least DIN A4 size).
- Online retailers are required to include the symbol on product pages and before checkout.
- Products themselves must continue to bear the crossed-out wheeled bin symbol.
Stricter Information Obligations
- Manufacturers and authorized representatives must provide written information with every shipment and additionally publish it online. This includes instructions on separate collection, safe removal of batteries/lamps, and the risks of lithium batteries.
- Retailers with take-back obligations must inform consumers even more clearly about return options, battery removal, and safety aspects—both on-site and digitally.
“Counter Model” at Municipal Collection Points
From now on, old devices may only be accepted by trained personnel.
Goal: To avoid incorrect disposal and reduce fire hazards from battery-powered devices.
Entlastung bei Meldepflichten
- Monthly volume reports for exports and own take-backs will be reduced to annual reports (deadline: April 30 for the previous year).
- Manufacturers can decide whether returned used devices are included in the calculation of collection volumes – this should be an incentive for more individual responsibility.
Calculation of the 400 m² Threshold
The actual shelf space will be used as a basis for take-back obligations, i.e. the square meters of the actual shelf space used, not just the footprint. Shelf and shipping areas at home and abroad must be considered.
Amendment of G4: Why Act Now?
The changes to the “ElektroG” bring increased administrative effort—especially for manufacturers. Be sure to check whether you need to make adjustments in information provision, take-back, etc. Missing deadlines risks fines, sales restrictions, and exclusion from online marketplaces.
Conclusion
Das ElektroG4 verschärft die Anforderungen an Hersteller und Händler, bietet aber gleichzeitig Bürokratieabbau bei den Meldepflichten. Wer sich frühzeitig vorbereitet, vermeidet Compliance-Risiken und sichert den reibungslosen Vertrieb seiner Produkte.
Noventiz supports you in the legally compliant implementation of all ElektroG obligations—from registration and volume reporting to take-back logistics. This way, you always remain legally compliant.
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