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German compliance answers / Compliance guides / Fines and enforcement

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Fine caps in the WEEE, battery and packaging laws: who is fined and how much

Short answer

The three laws cap fines differently: EUR 200,000 for no system participation under the packaging law, EUR 100,000 in most cases, and EUR 10,000 in other cases. These are statutory caps, not actual penalties. VerpackDG § 66 Abs. 3; ElektroG § 45 Abs. 2; BattDG § 60 Abs. 3

The key facts at a glance

Packaging: no system participation
Up to EUR 200,000. VerpackDG § 66 Abs. 1 Nr. 3; VerpackDG § 66 Abs. 3
Packaging: no registration
Up to EUR 100,000. VerpackDG § 66 Abs. 1 Nr. 1; VerpackDG § 66 Abs. 3
WEEE: no or late registration
Up to EUR 100,000. ElektroG § 45 Abs. 1 Nr. 1; ElektroG § 45 Abs. 2
Battery: breach of the sales ban
The EUR 100,000 tier. BattDG § 60 Abs. 1 Nr. 1; BattDG § 60 Abs. 3
Packaging: late change report
The EUR 10,000 tier (remaining cases). VerpackDG § 66 Abs. 1 Nr. 2; VerpackDG § 66 Abs. 3
Fine caps (EUR)Packaging: no system participation200,000Packaging: no registration100,000ElektroG: no or late registration100,000BattDG: breach of the sales ban100,000Packaging: late change report10,000
Figure 1. Fine caps (EUR)

What is the fine under WEEE law? (ElektroG § 45)

The EUR 100,000 cap applies to § 45(1) nos. 1 to 9 among others; the remaining cases are capped at EUR 10,000. ElektroG § 45 Abs. 2

What is the fine under battery law? (BattDG § 60)

Making a battery available in breach of the sales ban is in the EUR 100,000 tier. BattDG § 60 Abs. 1 Nr. 1; BattDG § 60 Abs. 3

A fulfilment provider storing, packing, addressing or shipping a battery of an unregistered producer is in the same tier. BattDG § 60 Abs. 1 Nr. 2; BattDG § 60 Abs. 3

What is the fine under packaging law? (VerpackDG § 66)

No system participation: up to EUR 200,000. VerpackDG § 66 Abs. 1 Nr. 3; VerpackDG § 66 Abs. 3

No registration: up to EUR 100,000. VerpackDG § 66 Abs. 1 Nr. 1; VerpackDG § 66 Abs. 3

Late or missing change reports: the statute puts these in the remaining cases, capped at EUR 10,000. VerpackDG § 66 Abs. 1 Nr. 2; VerpackDG § 66 Abs. 3

What is the fine under GPSR?

GPSR itself sets no amount: Member States lay down the rules on penalties. GPSR Art. 44

The German fines for GPSR breaches were not verified here, so no figure is given.

A cap is not a bill

These are the maximum amounts the law allows. The authority sets the actual amount case by case. Treat them as a measure of the cost of not complying, not a number you will certainly be fined.

What this guide did not verify

Not verified here: amounts in actual enforcement cases, the authorities' enforcement priorities, and the specific German fines for GPSR.

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What sellers also ask

Who fines?

Each law names its competent authority; this guide did not check them one by one.

Does the representative take the fine for me?

The law says the representative performs the manufacturer's duties in its own name, but how fine liability is shared depends on the contract and case; ask a German lawyer.

Where does each statement come from?

Every source below is a legal text or an authority page; click through to compare.

  1. BattDG § 60 Abs. 1 Nr. 1 · read 2026-10-18
  2. BattDG § 60 Abs. 1 Nr. 2 · read 2026-10-18
  3. BattDG § 60 Abs. 3 · read 2026-10-18
  4. ElektroG § 45 Abs. 1 Nr. 1 · read 2026-10-18
  5. ElektroG § 45 Abs. 1 Nr. 3 · read 2026-10-18
  6. ElektroG § 45 Abs. 1 Nr. 4a · read 2026-10-18
  7. ElektroG § 45 Abs. 1 Nr. 4b · read 2026-10-18
  8. ElektroG § 45 Abs. 1 Nr. 5 · read 2026-10-18
  9. ElektroG § 45 Abs. 2 · read 2026-10-18
  10. GPSR Art. 44 · read 2026-10-18
  11. VerpackDG § 66 Abs. 1 Nr. 1 · read 2026-10-18
  12. VerpackDG § 66 Abs. 1 Nr. 2 · read 2026-10-18
  13. VerpackDG § 66 Abs. 1 Nr. 3 · read 2026-10-18
  14. VerpackDG § 66 Abs. 3 · read 2026-10-18

This guide summarises public legal texts and authority pages as general information. It is not legal advice. For your case, ask a licensed German lawyer.

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