ElektroG3 and Diary dates in 2022

The Electrical and Electronic Equipment Act version 3 (ElektroG3) took effect on 01/01/2022. Please ascertain whether this results in any new obligations on your part. Below is a summary of the key new features of the ElektroG3 and key diary dates in 2022. We will keep you informed about further developments as they unfold.


Diary dates in 2022



Electrical and Electronic Equipment Act: The ElektroG3 took effect on 1 January 2022. take-e-way has compiled the key new features of this Act for you in a compact form. This is where you will find the ElektroG3 overview and relevant solutions. The overview covers the following topics:

Batteries Act:  Effective as of 1 January 2022, all manufacturers of batteries of any kind (device, industrial and vehicle batteries) are required to have registered with the EAR foundation (Stiftung Elektro-Altgeräte Register - EAR). This also applies to manufacturers who have already been reported to the Federal Environment Agency. Please note: Batteries contained in your electrical appliances must likewise be registered.

Packaging Act: With effect as of 1 January 2022, an extended deposit obligation came into force for disposable beverage packaging that is currently subject to system participation. Manufacturers of transport packaging, reusable packaging and other packaging that does not typically end up with private end-consumers after use now have an obligation to provide evidence of compliance with the take-back and recycling requirements. This is where you can find all packaging law deadlines and changes at a single glance.

France / Packaging: As you can read in detail here, the obligation to display the Triman logo together with the sorting information came into force on 1st January 2022 and has to be fulfilled by 9th March 2022 at the latest. However, in order to give the producers time to adapt, a transition period of one year following the release of the sorting guidelines by the French government is granted. This means, the sorting information will become compulsory on all packaging starting from the 9th September 2022. An extension of the deadline until the 9th March 2023 is granted to all packaging produced or imported before the 9th September 2022.

France/Amendments to packaging legislation: The following packaging elements are banned under the French Anti-Waste Act (AGEC) from 2022:

  • Plastic packaging and stickers for fruits and vegetables
  • Usage of mineral oils in packaging (Please note: If you cannot remove mineral oil from your packaging yet, it is possible to report mineral oil as part of your packaging. It will result in a malus contribution of 50 percent.).

France / EPR: This is where you will find an overview of the waste streams that are subject to EPR (Extended Producer Responsibility) as of 1 January 2022:

  • Toys
  • Oils
  • Sports and leisure equipment
  • Do-it-yourself and gardening equipment
  • Construction material

Please note that so far, not every waste stream has been assigned to a take-back system. We will inform you as soon as the systems are implemented.

Should you have any questions regarding France, please do not hesitate to contact Mr Quentin Dequet (+49/40/750687-126) or Ms Alina Eggert (+49/40/750687-166) via international@take-e-way.de.

Italy: Legislative Decree No 116/2020 imposed a strict labelling obligation on manufacturers and distributors of packaging in Italy. The interpretation of the decree, provided by CONAI (the national consortium for packaging) in the form of a guide, is now also available in German. Click here for a detailed interpretation of the environmental labelling obligation provided in German language. (The English version is available here.) As mentioned in our previous article on this subject, the entire labelling requirement was suspended until 31 December 2021. This is where you can find an overview of the details regarding the environmental labelling obligation in Italy.

Should you have any questions regarding Italy, please do not hesitate to contact Ms Medine Bayram (+49/40/750687-120) via international@take-e-way.de.



France / UIN: As stated in the article L541-10-13 within the law n° 2020-105 of the 10th February 2020, which came into force on the 2nd January 2022, the French government has decided to issue a Unique Identification Number (UIN) to every producer placing particular products on the French market. This UIN will be issued for every waste stream subject to Extended Producer Responsibility (EPR) in France. Please note that EPR in France is not limited to WEEE, batteries and packaging. There are more waste streams concerned (among others paper, furniture, textiles incl. shoes, tyres, household chemical products). Further particulars and contacts regarding the UIN / France are available here.



Electrical and Electronic Equipment Act:  Food retailers will be subject to the distributors’ take-back obligation in place since 2016 from 01/07/2022.

Packaging Act:  On 1 July 2022, further amendments to the Packaging Act will take effect, such as:

  • an extended registration obligation for all companies that place packaging filled with merchandise on the market, including a
  • registration obligation for ultimate distributors of service packaging and non-reusable packaging liable to a deposit as well as for manufacturers of transport and reusable packaging,
  • mandatory information on types of packaging at the time of registration, and
  • the new responsibilities of electronic marketplaces / platforms and fulfilment service providers.


  • Electrical and Electronic Equipment Act: According to the new requirement of Section 9 (2) sentence 1 ElektroG, in future all electrical and electronic equipment must be marked with the crossed-out dustbin icon (as is already the case in many other EU member states), whereas up to now only such equipment had to be marked with this icon for which a financing guarantee according to Section 7 (1) ElektroG had to be given (i.e. such equipment which can be used in private households). Accordance with Section 46 (2) ElektroG, this requirement applies to all equipment placed on the market in Germany as of 1 January 2023.
  • CE mark: For exports to the United Kingdom (England, Wales, Scotland), recognition of the CE mark for market access ceases to apply. It will then be finally replaced by the UKCA mark.



  • Packaging Act: Final distributors (with a sales floor space of over 80 sqm or more than 5 employees) of special service packaging in the food and catering sector are required to offer consumers reusable alternatives, to inform consumers about this and to offer the reusable alternatives on at least the same pricing and terms.


The consultancy team at take-e-way will be pleased to answer any questions you may have on the ElektroG3 as well as the diary dates and innovations listed here under beratung@take-e-way.de or +49/40/750687-0.

Sebastian Siebert

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0


Christoph Brellinger

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0


Services & Contact