WEEE and BattG Registration: A Country Guide for Importers
Extended producer responsibility is the part of an electronics import that buyers tend to discover late. The factory can build the device, book the test scope and print the label, but registration under WEEE, the German Batteriegesetz and the French EPR schemes sits with the importer of record in each market. That split is not a loophole; it is how the directives are written, and it shapes what you should ask a supplier for before the first purchase order. This article sets out who registers what, and where a manufacturer's help legitimately ends.
Why the importer is the producer
Under the WEEE Directive and the battery directive, the obligation falls on the entity that first places the product on the market in that member state. If you import from Shenzhen and sell into Germany, you are that entity. Your Chinese supplier is not the producer for EPR purposes, no matter how the invoice is written. The same logic applies in France, the Netherlands, the UK and Canada, though each has its own register, fee scale and reporting cadence. Buyers who assume the factory handles this end up with unregistered stock, which is a commercial problem rather than a technical one. Our how to vet a supplier guide covers the questions that separate a compliant supply chain from a hopeful one.
Who registers what, by market
The table below is a checklist of the registration and labelling duties that normally sit with the importer. It is not legal advice and the detail changes; treat it as the list you take to your compliance adviser or your national register.
| Market | Registration duty | Labelling duty | Who files |
|---|---|---|---|
| Germany | WEEE registration with the national register; separate battery producer registration under BattG | WEEE mark, battery collection mark, brand and registration reference | Importer |
| France | Registration with the relevant EPR scheme for electricals and for batteries | Triman mark plus sorting instructions for the product and its packaging | Importer |
| Netherlands | Registration with the national WEEE and battery schemes | Disposal marking and scheme reference | Importer |
| United Kingdom | Producer registration for electricals and for batteries; EORI and VAT position confirmed | Crossed-out bin mark and producer details | Importer |
| Canada | Provincial stewardship programme enrolment, which varies by province | Provincial programme marking where required | Importer |
| All markets | Keep technical file, test reports and battery documentation per hardware revision | Correct age grading where a toy scope applies | Importer holds, factory supplies |
What the factory can and cannot do
WingPhoenix can supply the documentation package that supports your registration: CE RED test evidence, RoHS 3 and REACH SVHC screening, battery UN38.3 summaries with the watt-hour rating printed on each unit, and EN 1811 nickel release data for skin-contact items. We can print the Triman mark and the sorting instructions you approve, and we can print your registration reference on the product or the packaging. What we cannot do is register in your name, because the register asks for a legal entity in that market. Any supplier who offers to "handle WEEE for you" is either misdescribing the arrangement or asking you to rely on a registration that is not yours. The CE RED document checklist shows the shape of the file you should expect per model and revision.
Practical order of operations
Registration should run in parallel with tooling, not after it. A workable sequence looks like this.
- Confirm the importer of record for each market and the entity that will hold the registration.
- Register with the national WEEE and battery schemes before the first shipment lands.
- Agree the label artwork: WEEE mark, battery mark, Triman and sorting instructions, registration reference, age grading.
- Collect the technical file per hardware revision, including battery test summaries and safety reports.
- Confirm the commercial terms that carry the goods, since the Incoterm decides who is the importer at the border.
That last point catches people out. Moving from DDP to EXW changes who clears the goods and therefore who is the producer for EPR purposes in some markets. Our MOQ, sampling and lead times page sets out the standard terms, and OEM versus ODM explains how much of the label and packaging you control in each model.
Where we help, and where you should say no
We help with the parts that belong to the manufacturer: test scope booked per hardware revision with an accredited laboratory, battery documentation, artwork execution and a consistent label across production batches. You should say no to a supplier who offers a registration number that is not in your company's name, who cannot produce a UN38.3 summary for the exact cell being shipped, or who treats the Triman mark as a decorative logo rather than a market-specific labelling duty. Toy scope is decided by the age grading printed on the packaging, so if the grading changes, the test scope changes with it. The factory page describes how we build and test, and the product catalogue lists the current models, including the health smartwatch range, where wellness metrics are guidance and never diagnosis.
Send us the specification for the model you intend to import, together with the markets and the entity that will register. We will return the documentation list for that hardware revision, the label artwork requirements for each market, and a quotation that states the Incoterm so the importer of record is unambiguous. Start with the contact form and we will confirm what we can supply and what remains with you.
Questions buyers ask
Who is responsible for WEEE and BattG registration when I import electronics into the EU?
The importer of record is the producer for EPR purposes in most EU member states, so the WEEE and battery registration sits with your entity, not with the factory. WingPhoenix supplies the technical documentation and battery test summaries you need, but cannot register on your behalf.
Does WingPhoenix print the Triman logo and sorting instructions on the packaging?
Yes, when you supply the artwork and confirm the target market, we print the Triman mark and the sorting information you have approved for that packaging revision. The wording and mark must be correct for the market, so the importer signs off the artwork before the print run.
Related: more on sourcing & compliance · buyer guides · customisation tiers