Bottom line:
- When a German buyer asks for WEEE, EAR or a WEEE-Reg.-Nr., they want producer registration for electrical and electronic equipment placed on the German market. LUCID is packaging. CE is product safety. A Responsible Person is a safety contact. None of those fill this box.
- The register is stiftung ear. A company with no German establishment cannot register itself. It must appoint a Germany-established authorised representative in writing. After ear confirms the mandate, that person performs the producer duties in their own name.
- Opening a Hong Kong store does not issue this number. On FOB to a German company the duty often sits with them. On DDP or sales to consumers the seller is more easily treated as the person placing the goods. Collection and guarantees follow the registration. There is no official euro price.
Sales forwards: “The customer wants a WEEE number. Cut-off is tomorrow.” The next email staples a LUCID, a Responsible Person contract and a CE declaration into one zip. The buyer replies that those are packaging and safety, not electrical recycling. Finance asks whether to buy a “Germany full set.”
How packaging is registered is on LUCID. Whose name goes on the pack as the safety contact is on GPSR Responsible Person. Composition is on REACH / SVHC. How a battery ships is on the transport gate. The electrical-recycling box is the one that stops this order: who places the equipment, who holds the number, and how the representative is appointed.
1. The four things they name are not one certificate
Germany’s Electrical and Electronic Equipment Act (ElektroG) writes producer responsibility for equipment placed on the German market. Registration, quantity reports, take-back and an insolvency-proof guarantee run through stiftung ear. Buyers and platforms call the pack WEEE, EAR or a German electrical number.
| What they say | What it is | Issued with a Hong Kong store? |
|---|---|---|
| WEEE / EAR / WEEE-Reg.-Nr. | The electrical-recycling number stiftung ear issues to a registered producer; check it on the ear list | No. No German establishment, no self-registration |
| LUCID / eco fee | Packaging placed on the German market | No. That is LUCID |
| CE / DoC | Product-safety conformity under the applicable directives | No. CE does not say who pays for take-back |
| GPSR Responsible Person | A Union product-safety contact | No. That contract is not an ElektroG authorised representative |
After the table, open the inquiry. If they ask for “your German number,” ask whether they mean packaging, electrical equipment or batteries. Batteries have a separate German BattG register. Do not put an electrical number in a battery box, or a packaging number in an electrical box.
2. Without a German establishment you cannot register at ear yourself
stiftung ear states that a foreign company that wants to place equipment on the German market cannot register itself. It must appoint an authorised representative (Bevollmächtigter) established in Germany, who performs the producer duties in their own name. Registration moves only after ear confirms that mandate. The official note is Applying for WEEE-registration as a foreign company.
The representative must have an establishment in Germany. A producer may appoint only one representative for all brands and all equipment types at the same time. The mandate must last at least three months, be in writing, in German, and signed by both parties. When it ends, the representative reports the end in the ear portal; ear confirms it and then revokes the registrations. To change representative, end the old mandate first. Two people cannot sit in parallel.
What counts as an establishment in Germany: ear says a branch entered in the commercial register, with proof of a permanent establishment, staff and equipment, used to carry on an independent occupation for an indefinite period. A German tax number (St.-Nr.) is required to recognise a branch. A subsidiary is not a branch of the parent; if the subsidiary places goods on the market, it may itself be a producer.
A Hong Kong serviced office, a registered office and a German mailbox do not fill that seat. A platform membership does not gift a German branch.
3. Who “places electrical equipment on the German market”
ElektroG treats as a producer the person who manufactures in Germany and places, or who buys from abroad and then places, equipment on the German market. Distance sales count. A Hong Kong company on Alibaba.com usually meets one of two stories. Do not collapse them into “every cross-border sale must register.”
FOB / CIF, a German company as importer, goods to their warehouse. The first placing is usually that German company. The legal duty often sits with them. A commercial invoice and a packing list do not by themselves make you the ElektroG producer. If they ask for “your WEEE number,” ask whether it is for their importer, the platform or the forwarder.
DDP, parcels, sales to German consumers. Equipment that first appears at the end user is more easily treated as placed by the seller. Then a WEEE-Reg.-Nr. is no longer “the buyer’s problem.” Who clears and who pays the duty is on DDP / DAP. A DDP quote does not issue an electrical number.
Luminaires, small appliances, wearables with a charge, and cabinets with a motor can all fall into an electrical category. The category follows ear’s equipment types that day. A poster that says “electronics” is not a filing. If the shop-floor photo shows a plug, a motor or a control board, ask the electrical question first, then whether a battery filing is also due.
4. Once the number is issued, where it is shown
After registration, the authorised representative appears on the list of registered producers as acting for you. Buyers, platforms and forwarders match the number and the legal person on the ear list, not a chat screenshot. How the number is shown on invoices, a web shop or the pack follows ElektroG and ear that day. Do not invent a “certified” mark.
A CE mark, a Responsible Person address and the Hong Kong company name answer other questions. A box already printed with “EU Responsible Person” and a Green Dot can still be refused: the buyer wants to know who funds take-back for this appliance. A LUCID-related mark on the outer carton does not replace the electrical number.
Sending a PDF while the goods are unmarked still fails at the store. Printing a mark without a registration still leaves the platform questionnaire empty. Do the two steps separately.
5. The packs finance and the shop floor mix up
Putting LUCID in an electrical questionnaire. Reviewers match the register. A packaging number will not pass ear. An electrical number will not pass LUCID.
Using the factory’s German customer number on your store. A WEEE-Reg.-Nr. sits on the registered legal person. A Dongguan factory’s number is not the Hong Kong seller’s. The buyer’s own number does not go in your terms.
Retitling a GPSR Responsible Person contract as the authorised representative. A safety contact may sit anywhere in the Union. An ElektroG representative must sit in Germany and be confirmed by ear. An English Responsible Person contract will not pass the ear portal.
Buying a “German electrical full-year pack” before you know who places the goods. An FOB bulk order may only need you to give model, category and quantity. Open the inquiry: company or consumer, who imports, and whether they want packaging, electrical equipment or batteries.
Writing the take-back cost into the unit price as an official rate. Guarantees and collection follow the registration and the quantities. The figure sits in that arrangement. Do not copy a forum euro-per-kilo, and do not write “German WEEE included.”
Treating UN38.3 or an MSDS as the recycling registration. Those are transport. A battery that can fly is not a German market electrical number.
6. How the inquiry can be answered
| They write | A usable reply | Do not write |
|---|---|---|
| Send your WEEE / EAR number. | Please confirm whether your company is the importer placing the equipment on the German market. If yes, registration usually sits with you. We are the Hong Kong seller and can give equipment category and quantity for your ear filing. | Send a LUCID or a Business Registration number as the WEEE-Reg.-Nr. |
| You already have GPSR on the box. | The Responsible Person address and the electrical-recycling number are two files. The safety contact follows the Responsible Person arrangement. Recycling registration follows who places the goods in Germany. A seller with no German establishment cannot collect a number at ear. | A Responsible Person equals WEEE. |
| DDP to a German home address; recycling is in the freight. | DDP says who clears and pays duty. It does not issue an electrical registration. Whoever places the goods gets the number. Collection and guarantees follow the registration; they are not an official freight line. | DDP includes every German certificate. |
| Use the factory’s WEEE number on your Alibaba store. | The number sits on the registered company name. A factory number cannot fill a Hong Kong seller’s store. If we register ourselves, we first appoint a Germany-established authorised representative. | Borrow the customer’s or the factory’s number for now. |
Do not write “German WEEE registered” or “electrical recycling certified” on a showcase. You can say the seller is a Hong Kong company, that category and quantity are given with the order, and that registration sits with the party that places the goods.
7. If you already replied “we have German WEEE”
- Tell sales the same day: prices that say “certified / recycling included” stop.
- Open this German order: company or consumer, who imports, FOB or DDP, and whether they want LUCID, WEEE or batteries.
- Keep LUCID, Responsible Person, VAT, REACH and transport papers as their own files. Do not merge and retitle.
- If you will register: appoint a Germany-established authorised representative in the Hong Kong company’s name, in a German written mandate. Do not hand the master account to an intermediary.
- If the goods are already moving: send the equipment description that matches. Do not invent a WEEE-Reg.-Nr. to pass a review.
The membership still buys the file and the showcases. Wire it to ALIBABA.COM HONG KONG LIMITED. Corpable does not register at ear, appoint the representative or post a take-back guarantee. What the platform reviews, and whether ear issues a number, follows their process that day. Do not write a penalty figure into the contract.
Questions teams actually ask
Can we send a LUCID number as the WEEE registration?
No. LUCID is the German packaging register. A WEEE-Reg.-Nr. is issued by stiftung ear under the Electrical and Electronic Equipment Act (ElektroG). A packaging number will not fill an electrical box, and an electrical number will not fill a packaging box.
Does opening Alibaba.com on a Hong Kong company issue an EAR / WEEE number?
No. The membership buys showcases, not a German electrical registration. Without an establishment in Germany you cannot register at ear yourself. You first appoint a Germany-established authorised representative in writing, who performs the producer duties in their own name.
Can a GPSR Responsible Person contract stand in as the ElektroG authorised representative?
No. The Responsible Person is the Union product-safety contact. The ElektroG authorised representative is the Germany-established person ear confirms to perform electrical-recycling duties for you. Two contracts. A serviced-office address fills neither.
If we sell FOB to a German company, do we still need WEEE?
In law, the person who places the equipment on the German market may be the producer. On FOB, when the buyer imports, the duty often sits with the German buyer. If they ask for “your WEEE number,” ask whether it is for their importer, the platform or the forwarder.
Can the showcase say “German WEEE certified / recycling included”?
Not without a matching WEEE-Reg.-Nr. and an ear listing. Collection and guarantees follow the registration. There is no site-wide official euro price. Writing “included” will be screenshotted back at you.
Can Corpable register at ear for us, or guarantee that German orders will open?
No. An advisor can help you see whether the buyer wants a packaging number or an electrical number. We do not appoint the representative, post a guarantee, or promise a platform or buyer review. Membership fees still wire to ALIBABA.COM HONG KONG LIMITED.
Related reading
- German packaging: LUCID is not a Responsible Person
- EU Responsible Person: a Hong Kong address is not enough
- REACH is not a CE file
- Batteries: the transport gate
- Contact Corpable · info@aliad.hk
Written by Corpable Marketing Limited for Alibaba.com Hong Kong-channel sellers. Not legal, tax, or audit advice. Platform, customs, bank, and auditor outcomes follow the latest official notices. Membership fees go to ALIBABA.COM HONG KONG LIMITED. Corpable does not collect them.