Direct answer: WEEE and EPR registration is not a product certificate. It is a company registration, filed separately in every country where goods are first offered, and it must exist before the first unit sells – not after the first container ships. In Germany that means a stiftung ear WEEE number for the fixture plus a LUCID number for the carton. In France it means a separate ADEME UIN for each waste stream plus a representative with a French SIREN. None of these numbers is issued to the factory that built the product.
That is where sourcing budgets break. Buyers treat registration as one more line in the supplier’s certificate pack and ask for it three weeks before delivery. It is not transferable, it is not quick, and in Germany it is illegal to offer the product while the application is pending.
The producer is whoever puts the goods on the market first
Under the WEEE Directive 2012/19/EU, obligations attach to the producer, and every member state defines that term broadly. Germany’s ElektroG covers importers and foreign online sellers, and a distributor offering equipment from an unregistered producer can itself be treated as the producer. France reaches the same result through Article L.541-10 of the Environmental Code and the 2020 AGEC law.
On a lighting order there are only three arrangements:
- EU importer sells under its own brand. The importer registers, carries the guarantee and owns the number. Your job as the supplier is to feed it data.
- EU importer resells your brand. The importer registers, but the entry records your brand and device type, so it will ask you to confirm that nobody has already registered that brand in that country.
- You sell direct through a marketplace. Then you are the producer in every country you ship to, and you need an authorised representative established there. No volume threshold removes this.
A European customer asking “do you have WEEE?” is not asking for a test report. They are asking whether someone in the chain has completed a company registration, and whether it will survive a marketplace audit.
Germany: the number has to be visible before the first offer
Section 6(1) ElektroG requires registration with Stiftung Elektro-Altgeräte Register before the product is placed on the market, filed per brand and per device type. Section 6(3) requires the number when the product is offered and on invoices; missing it is an offence carrying a fine of up to EUR 100,000 under Section 45(1). Competitors use this routinely – a missing number is one of the cheapest grounds for a cease-and-desist letter in Germany.
Timing is the real constraint. EAR publishes a ten to twelve week processing window, applicants report eight to ten in normal conditions, and there is no fast track. Registering in the month you book freight is a delay waiting to be found at the port.
Consumer-facing producers must also post an insolvency-proof guarantee so that collection and treatment are funded even if the company disappears – a bank or insurance product priced against declared volumes.
The category you register in changes the cost. Since 15 August 2018 the open scope uses six categories, and lighting splits across three of them:
- Category 3, lamps – LED tubes and lamps supplied as light sources, 80% recycling target.
- Category 4, large equipment – anything with an external dimension over 50 cm. A 600 x 600 panel and a 1.2 m linear belong here, even though they feel like small products.
- Category 5, small equipment – nothing over 50 cm, such as a 300 mm downlight. 75% recovery and 55% recycling target.
Two consequences follow. A catalogue that moves from 600 mm downlights to 600 x 600 panels changes category, and therefore the fee basis. And if you ship luminaires plus the lamps that go inside them as separate SKUs, that is two registrations, not one.
The carton is a second, separate register
German packaging sits under the Verpackungsgesetz, not ElektroG. Anyone putting sales packaging into circulation registers with the Zentrale Stelle Verpackungsregister through LUCID, then licenses the actual tonnage with a dual system. Registration has been mandatory since 1 January 2019, and the 2021 amendment widened the scope so that, since mid-2022, essentially all packaging – including transport packaging – must be registered and licensed.
The fee is charged by material weight, so this is a real cost line for a luminaire importer. An aluminium extrusion and a double-wall carton bill differently, and a heavy linear fixture can carry several kilograms of packaging per unit. Over-declaring wastes money; under-declaring surfaces in an audit two years later with interest. Marketplaces check both registers before a listing goes live, which is why the LUCID and WEEE numbers sit in the same seller dashboard. For the design rules layered on top of registration, see our guide to PPWR packaging requirements for lighting.
France: one UIN per stream, and a French address
France runs the strictest version of this system in Europe. Registration goes through ADEME’s SYDEREP platform, but only after you join an approved eco-organisation, and the output is a Unique Identification Number – the UIN – rather than a register entry.
France does not issue one number per company. Each waste stream is registered separately: household EEE, professional EEE, lamps, batteries and packaging each carry their own UIN. A lighting importer selling luminaires, replacement lamps and battery-backed units into France can be looking at four registrations before packaging is counted.
Non-French companies cannot register directly. You need a representative established in France with a SIREN number to sign the eco-organisation contract and hold the account – a recurring cost, because that representative is legally exposed to your declarations.
Two marking rules attach. Triman plus Info-tri sorting information must appear on the product or its packaging; the old Green Dot is no longer accepted as the French sorting mark. And for household EEE the eco-contribution has to be a separate line on invoices, quotes and the product page, not folded into the price.
Side by side: what each market actually demands
| Requirement | Germany | France |
|---|---|---|
| Register held by | Stiftung EAR (WEEE), ZSVR/LUCID (packaging) | ADEME SYDEREP, via an eco-organisation |
| Identifier | WEEE-Reg.-Nr. DE plus eight digits; LUCID number | UIN, one per waste stream |
| Number must appear on | Offers and invoices | Invoices, website, marketplace profile |
| Local representative for non-EU sellers | ElektroG authorised representative | Representative with a French SIREN |
| Financial guarantee | Insolvency-proof guarantee for B2C producers | Handled through the eco-organisation contract |
| Marking | Crossed-out bin symbol | Crossed-out bin, Triman, Info-tri |
| Eco-fee as separate invoice line | Not required | Required for household EEE |
| Typical first-registration lead time | 8-12 weeks | Commonly 2-4 weeks once the file is complete |
Where the money actually goes
| Cost line | Charged by | Priced per | Recurs |
|---|---|---|---|
| Registration and brand/type entries | stiftung ear | Entry and each change notification | Every new brand or device type |
| Insolvency-proof guarantee | Bank or insurer | Declared annual volume | Annually, adjusted |
| Collection and recycling share | stiftung ear allocation | Category and market share | Monthly or annual reporting |
| Packaging licence | Dual system | Kilograms by material | Annually, against forecast |
| French membership and eco-contribution | Ecosystem, Ecologic, Citeo | Fixed fee plus per-unit share | Annually, UIN renewed |
| Authorised representative | Service provider | Per country, per stream | Annually |
Batteries: the third registration nobody scopes
If the fixture contains a battery – emergency backup or a wireless sensor pack – that battery is regulated separately under Regulation (EU) 2023/1542. It has applied since 18 February 2024, repealed the old Batteries Directive on 18 August 2025, and its producer responsibility chapter took effect the same day.
Producers register in every member state where they first make a battery available, including batteries built into equipment, and distance sellers appoint an authorised representative for producer responsibility in each of those states. Germany moved from three battery categories to five on 18 August 2025.
The labelling clock is still running: the separate-collection symbol has applied since 18 August 2025, the general information label is due from 18 August 2026, and the QR code and battery passport follow from 18 February 2027. Supply-chain due diligence was pushed back to 18 August 2027. For an emergency luminaire with a LiFePO4 pack, the file therefore carries EEE registration, battery registration and packaging – three streams for one SKU.
What the OEM should hand over
You cannot register on your customer’s behalf, but you can make their registration fast or slow. The pack that clears in one pass contains: net and gross weight per SKU; packaging weight by material per carton; battery chemistry, capacity and weight where fitted; the brand and model list exactly as printed on the label; and a one-page statement of who is the first placer in each market.
That last document matters more than it sounds. When a marketplace audit asks an importer to prove a brand is not registered elsewhere, a manufacturer’s letter settles it in a day. Without one, the listing comes down while emails circulate.
Four things buyers still get wrong
- Treating one EU number as EU-wide. A German WEEE registration has no standing in France.
- Asking the factory to “provide WEEE”. The factory provides data; the registration belongs to the first placer.
- Forgetting the carton. Two registers, two fees, both checked at listing.
- Assuming professional products are exempt. France separates household and professional EEE streams; professional is a registration, not an exemption.
For the safety side of the same file, see LED lighting certifications for importers.
Frequently asked questions
Can our German WEEE number be used for France?
No. Producer responsibility is implemented nationally and each member state keeps its own register. A German WEEE-Reg.-Nr. has no validity in France, and a French UIN has no validity in Germany. Selling into both means two sets of registrations and two sets of declarations.
Does the Chinese manufacturer register, or the EU importer?
Whoever first places the goods on that national market. If an EU importer buys and resells, it registers. If you sell direct to end users through a marketplace, you are the producer and register through an authorised representative. In both cases the manufacturer supplies the technical and weight data.
Is a 600 x 600 panel small or large equipment?
Large. Category 4 covers equipment where any external dimension exceeds 50 cm, and a 600 mm panel does. A 300 mm downlight falls into category 5. Category determines the collection share and recycling target applied to your volumes.
Can we ship while the German registration is pending?
No. Offering or placing the product on the market before the number is issued is not permitted, and the waiting period counts. With a ten to twelve week window, registration has to start before the purchase order, not after it.
Do these rules apply to professional and B2B products?
Yes. They attach to equipment placed on the market, not only to consumer sales. France handles professional EEE as a distinct stream with its own UIN and eco-organisation contract; the eco-fee display rule is lighter than for household EEE, but registration is not optional.
This article is a procurement guide, not legal advice. Confirm requirements for your specific product and market with a qualified compliance provider.
