Take-back symbol in online shops: ElektroG duty since July

Since 1 July 2026, retailers who are obliged to take back old appliances no longer have a transition period: anyone selling electrical or electronic equipment online must display the symbol under Annex 3a ElektroG on the product pages or before or at the time of ordering, clearly visible and legible (§ 18a(4) sentence 1 ElektroG). The rule is easily confused with the crossed-out wheelie bin printed on the devices themselves. This article explains the key dates, which symbol is meant, where it belongs and who is covered by the wording, and shows how symbol, take-back information and collection option can be generated from product data in Shopware. For retailers in e-commerce for electronics and technology, this affects every product page. The article is not legal advice; it shows what the law says and where there is room for interpretation.

Two dates, two meanings: 1 January and 1 July 2026

The rule comes from the Second Act amending the Electrical and Electronic Equipment Act of 25 November 2025 (BGBl. 2025 I Nr. 286). Its Article 1, which contains the amendments to the ElektroG, entered into force on 1 January 2026 (Art. 4(2) of the amending act). Since then, § 18a(4) sentence 1 ElektroG has required distributors who offer electrical or electronic equipment by means of distance communication to place the symbol under Annex 3a on the pages with the relevant products or before or at the time of ordering, clearly visible and legible. It refers to a uniform nationwide sign for collection and take-back points that looks the same in a physical store, at municipal collection points and in an online shop. The idea is that customers can see at a glance where to hand in old appliances, whether they buy in a store or online.

Some retailers were given extra time. Under § 46(2) ElektroG, distributors obliged to take back under § 17(1), (1a) and (2) sentence 1 had until the end of 30 June 2026 to implement the labeling and information requirements under § 18a(2) to (4). In the draft bill, the Federal Government justified the period with the organisational lead time needed for labeling and set six months for it (Bundestag printed paper 21/1506). The provision has therefore applied since 1 January 2026, and the transition period for retailers obliged to take back ended on 30 June 2026. Since 1 July 2026 they too must show the symbol without delay.

Which symbol is meant: Annex 3a, not the wheelie bin

The law calls the sign in Annex 3a the "symbol for labeling collection and take-back points"; § 18a(1), (2) and (4) refer to it. The logo carries the German lettering "Elektrogeräte Rücknahme" (electrical appliance take-back), the name stiftung ear also uses in its statement on the amendment. The design is fixed: letters in gray, the sign in green. In single-color use, letters and the green part are reproduced in 100 percent black (Annex 3a ElektroG). The law prescribes color and a minimum format only for physical stores: there the symbol must hang in color and at least in DIN A4 format in the entrance area (§ 18a(2) ElektroG). The online shop has no such requirement; the symbol must be clearly visible and legible. The annex does not provide for variations such as a sign recoloured in the shop's brand color.

The crossed-out wheelie bin is a different sign with a different purpose. It is the Annex 3 symbol for the separate collection of electrical and electronic equipment, a crossed-out wheeled waste bin (Annex 3 ElektroG), and corresponds to the symbol laid down in Annex IX of the European WEEE Directive 2012/19/EU. Under § 9(2) ElektroG, devices are permanently marked with it when placed on the market. Only where the size or function of the device exceptionally requires it does the symbol move to the packaging or to accompanying documents such as the instructions for use. This marking is the job of whoever places the device on the market, usually the manufacturer or importer; a retailer selling branded goods that are already marked does not have to add anything to the device.

Online, the wheelie bin appears only as an explanation. In a physical store, § 18a(3) requires the sign in the immediate vicinity of where electrical equipment is sold, together with a note on separate disposal. In distance selling, by contrast, the meaning of the Annex 3 symbol is part of the consumer information under § 18(3) sentence 1 item 7. Anyone selling at a distance publishes this information from the first offer onwards, clearly visible and easy to find in the media they use, or encloses it in writing with the shipment (§ 18(3) sentence 2 ElektroG). The duty itself is not new: the information requirement existed before 2026. The amendment added in sentence 2 that the information must be easy to find, and extended the list in sentence 1, among other things with the risks of lithium batteries and the duty to remove lamps (BGBl. 2025 I No. 286). As with the energy label requirements in online shops, data maintenance decides whether the information appears in the right place.

Where the symbol has to appear in the shop

The law allows two places: the pages with the relevant products or the ordering process, before or at the time of ordering. In its statement, stiftung ear phrases it a little more loosely as "clearly visible and legible" (German: "deutlich sicht- und lesbar"); the statutory wording "gut sicht- und lesbar" remains decisive. Both aim at the same thing: the sign should be noticed where the purchase decision is made. A small logo in the footer between payment methods and trust seals is unlikely to count as clearly visible, and a graphic behind a collapsed tab usually meets the requirement less clearly than a display right next to the buy box. These positions have proved themselves:

• Product detail page: in or directly below the buy box, visible without scrolling or expanding.
• Category page and search results: additionally as a small attribute on the product tile if customers can add to the cart directly there.
• Cart and order summary: as a note before submission, so that the "before or at the time of ordering" option is also met for quick purchases.
• Confirmation email: useful as a repetition, but too late to satisfy the "before or at the time of ordering" requirement on its own.
• Own apps and catalogs with an ordering function: for consumer information, the law speaks of the media used, not only of the website.

Unlike in a physical store, where the symbol must hang in color and at least in DIN A4 format in the entrance area, the law prescribes neither size nor color online, only a location and legibility. The symbol should therefore be large enough for the lettering to remain legible on a smartphone, and it should not disappear in an image gallery. We implement it as a separate element with alternative text and a text link to the take-back page, not as part of the product image: a symbol inside the product photo would have to be maintained with every image change and would be invisible to screen readers.

Who is covered: wording and an open question of interpretation

The wording of § 18a(4) sentence 1 addresses distributors who offer electrical or electronic equipment by means of distance communication. The sentence does not mention any area threshold. This sets it apart from the preceding subsections: the duties in physical stores under § 18a(2) and (3) expressly apply only to distributors obliged to take back under § 17(1) sentence 1 or (1a). Taken literally, the wording would cover every online retailer with electrical equipment in its range, including the small specialist shop that sells a few lamps or chargers on the side. The same applies to § 18(3) sentence 2, which also assigns the publication of the consumer information to all distance sellers.

There are, however, reasons for a narrower reading. The second sentence of the same subsection requires information on how collection under § 17(2) sentence 2 and take-back under § 17(2) sentence 4 work. Both apply only to retailers obliged to take back. The transition period under § 46(2) also refers only to those obliged to take back. None of the sources evaluated here settles the question. We therefore consider it open, and that has a practical consequence: anyone relying on the narrow reading bears the risk that an authority or a court sees it differently. Anyone who shows the symbol has taken precautions with manageable effort. Many retailers already know a similar trade-off from the EU Battery Regulation and the German Battery Act, where manufacturer and retailer duties also overlap.

Since an existing take-back obligation of the respective distributor is not immediately apparent to consumers, but depends on the respective sales or storage area, there is a need to label take-back points in retail uniformly.

Federal Government, draft bill, Bundestag printed paper 21/1506, explanatory memorandum on § 18a ElektroG (own translation)

The explanatory memorandum shows what the symbol is for: consumers should see where they can hand in old appliances, because the take-back obligation depends on the retailer's area. Under § 17(1), this threshold is at least 400 square meters of sales area for electrical and electronic equipment; for food retailers who offer electrical equipment several times a calendar year or permanently, it is 800 square meters of total sales area. In online retail, all storage and shipping areas for electrical and electronic equipment count as sales area (§ 17(2) sentence 3 ElektroG). Anyone close to the threshold should measure and document these areas properly once, because the entire take-back obligation depends on them.

Take-back in distance selling: collection and return

The symbol is only the visible side of the duty behind it: the take-back itself. If a retailer obliged to take back delivers a new device to a private household, the household counts as the place of handover for the one-for-one take-back; collecting the old appliance is then free of charge for the end user (§ 17(1) sentence 2 ElektroG). In distance selling, however, this collection is limited to devices in categories 1, 2 and 4 (§ 17(2) sentence 2 ElektroG). Category 4 covers large equipment with at least one external dimension of more than 50 centimeters. Anyone delivering such devices by freight forwarder must therefore plan the collection into the delivery process, with appointment scheduling, carrying help and return transport. How delivery methods with appointments and additional services can be set up in the shop is shown in our article on freight shipping of bulky goods in the online shop.

A different route applies to categories 3, 5 and 6 and to small old appliances. Here, distance sellers obliged to take back ensure take-back through suitable return options within reasonable distance of the end user (§ 17(2) sentence 4 ElektroG). This also concerns take-back without a new purchase: retailers obliged to take back accept old appliances with no external dimension larger than 25 centimeters free of charge even if the customer buys nothing, limited to three old appliances per type of equipment. This is typically implemented through drop-off points or a return shipping procedure. Customers must be able to read in the shop which route has been chosen, because that is exactly what § 18a(4) sentence 2 requires.

In addition to the symbol, the shop therefore needs a page that describes both routes. Under § 18a(4) sentence 2, distance sellers provide information on how collection and take-back work. Unlike the symbol, this information is subject to fines: anyone who fails to provide it, or provides it incorrectly or incompletely, commits an administrative offense under § 45(1) item 13d. The link from the symbol to this take-back page connects the two. The page should avoid legal jargon: customers want to know whether the old fridge will be taken away and where they can hand in an old toothbrush.

The symbol in Shopware: product data instead of manual work

In a shop with a large range, manual work is not an option. Which products show the symbol should come from the master data, not from a list someone maintains on the side. In Shopware, a custom field on the product is the obvious choice, for example a switch "electrical or electronic equipment under ElektroG", filled together with the equipment category from the ERP system or a PIM system. The field then controls every place where the symbol should appear: buy box, product tile, cart line item and order summary. Where variants are involved, the attribute belongs on the main product and is inherited so that no variant is delivered without the symbol. The following example shows the buy box extension in a dedicated plugin:

{% sw_extends '@Storefront/storefront/page/product-detail/buy-widget.html.twig' %}

{% block page_product_detail_buy_container %}
    {{ parent() }}

    {# Symbol under Annex 3a only for electrical and electronic equipment #}
    {% if page.product.translated.customFields.xt_elektrog_anlage3a %}
        <div class="xt-elektrog-hinweis">
            <img src="{{ asset('bundles/xtelektrog/img/symbol-anlage-3a.svg', 'asset') }}"
                 alt="Symbol under Annex 3a ElektroG: electrical appliance take-back"
                 width="96" height="48">
            <a href="{{ config('XtElektroG.config.takeBackPageUrl') }}">
                Take-back and collection of old appliances
            </a>
        </div>
    {% endif %}
{% endblock %}

A few details decide whether the implementation holds up. The symbol is embedded as an SVG in the prescribed colors, letters in gray and the sign in green, so that it stays sharp on high-resolution displays; fixed width and height values prevent the buy box from jumping while loading. The customization sits in its own plugin rather than in the core or the theme; it usually survives updates without rework, as we describe in the article on preparing for the Shopware 6.8 upgrade. In our experience, the registration number also comes up: it is a manufacturer duty, and every manufacturer states it when offering products and on invoices under § 6(3) ElektroG. It only affects retailers who count as manufacturers themselves, for example when importing or selling an own brand.

Checkout and collection: where the information belongs

The ordering process takes more effort than the symbol if the shop sells large appliances. If a retailer obliged to take back delivers a device in category 1, 2 or 4 to a private household, collecting the old appliance is free of charge for the customer. In Shopware, this can be set up as a checkbox "Collect old appliance on delivery" that only appears if the cart contains such a device; the choice is written to the order and passed on to the warehouse and the freight forwarder. The Annex 3a symbol sits next to it in the order summary and there satisfies the "before or at the time of ordering" option. Anyone expecting promotional days with heavy traffic should load-test such additional steps beforehand; how a virtual waiting room for Black Friday traffic peaks relieves the ordering path is shown in another article this week.

• Annex 3a symbol on every product page with an electrical device and in the order summary.
• Text link from the symbol to the take-back page (§ 18a(4) sentence 2).
• Collection option only for categories 1, 2 and 4 when a new device is delivered.
• Return routes for categories 3, 5 and 6 named.
• Take-back of small old appliances up to 25 centimeters without a new purchase described.
• Consumer information under § 18(3) published in an easy-to-find place or enclosed.

What violations can cost: the range of fines under § 45

When it comes to fines, a close look at the catalog pays off, because it is narrower than some summaries suggest. The missing symbol itself, a breach of § 18a(4) sentence 1, is not listed in the catalog of § 45(1) ElektroG. By contrast, the information on collection and take-back under § 18a(4) sentence 2 is subject to fines: failing to provide it, or providing it incorrectly or incompletely, is an administrative offense under item 13d, with fines of up to 10,000 euros. The same applies to the consumer information under § 18(3), whose absence can be punished under item 13b, also with up to 10,000 euros. Under § 45(2), the higher range of up to 100,000 euros applies to items 1 to 9, 12 and 13a, including failure to take back. Whether a missing symbol can also be challenged under competition law is not answered by the sources evaluated here. Gaps in the information are expressly sanctioned, which is why symbol and take-back information belong together.

Why the legislator is tightening the rules: the collection rate

Behind the labeling lies a volume problem. Under § 10(3) ElektroG, the total weight of collected old appliances has been required since 1 January 2019 to amount to at least 65 percent per year of the average weight of the equipment placed on the market in the three preceding years. The target implements the WEEE Directive, which alternatively allows 85 percent of the waste equipment generated as the reference value (Art. 7(1) Directive 2012/19/EU). According to the German Environment Agency (Umweltbundesamt), the collection rate in Germany in reporting year 2024 was 28.7 percent, calculated using method A. The 65 percent is a target for the total volume in the country, based on equipment placed on the market, not a quota that an individual retailer would have to meet.

The absolute figures for reporting year 2024 make the gap tangible: according to the German Environment Agency, 3,176,883 tonnes of electrical and electronic equipment were placed on the market and 919,734 tonnes of old appliances were collected, of which 838,375 tonnes came from private households. As in the previous year (29.5 percent), the rate was well below the level of the years 2019 to 2021, which ranged from 44.3 to 38.6 percent (German Environment Agency). In the draft bill of September 2025, the Federal Government noted that Germany, with a collection rate of 38.6 percent in reporting year 2021, was well below the European target (Bundestag printed paper 21/1506). The uniform symbol is one building block to help consumers recognize take-back points more easily, in stores and online alike.

Provisional figures from stiftung ear are available for 2025. According to them, 960,540 tonnes of old appliances were collected, over 33,000 tonnes more than in 2024 (stiftung ear). The quantity placed on the market rose in the same year to around 3,386,806 tonnes. For distributors who send returned old appliances for treatment or disposal themselves, the take-back volume grew by just under 6,000 tonnes, or around 9 percent (stiftung ear). These annual figures are not final, because they are still merged with surveys by the Federal Statistical Office for the EU report. They are also defined differently from the rate published by the German Environment Agency; no collection rate for 2025 can be calculated from them, and a comparison with the agency's 2024 figures would not be reliable.

Outlook: what may still come

The amendment need not be the last change for online retail. In its recommendation for a decision, the Bundestag environment committee stated that it should be examined how manufacturers and in particular online retail can be given greater responsibility for achieving the collection targets (Bundestag printed paper 21/2635). This is a mandate to examine without a deadline, not an adopted law. European law leaves room for it: under Art. 14(5) of the WEEE Directive, member states may require manufacturers or distributors to inform users themselves, for example at the point of sale. As a side note: by the end of 31 December 2026, the Federal Government is examining under § 22(4) ElektroG whether a recycling rate for plastics from old appliances will be introduced. Anyone who controls mandatory information from product data today responds to such changes with data maintenance instead of a rebuild.

Checklist for your shop

• Review the range: which items are electrical or electronic equipment under the ElektroG, and which are accessories without their own electrical function?
• Clarify areas: do the storage and shipping areas for electrical equipment reach 400 square meters? Then § 17(1) imposes a take-back obligation.
• Embed the symbol: Annex 3a in gray and green or single-coloured in 100 percent black, as a separate element with alternative text (Annex 3a ElektroG).
• Create the take-back page: describe collection and return as they actually work in your business (§ 18a(4) sentence 2).
• Align the consumer information: meaning of the wheelie bin and the other details under § 18(3) easy to find.
• Coordinate collection with the freight forwarder: appointment, carrying help, return transport, handover for disposal.
• Clarify the registration number: only manufacturers, for example importers or own brands, state it when offering and on invoices (§ 6(3) ElektroG).
• Have it checked from the outside: a shop check shows whether symbol, take-back page and checkout fit together.

How we approach this

We start with an inventory: which items are affected, how are they flagged in the ERP or PIM, where does the symbol appear today, and which take-back routes actually exist in the business. We then create the product attribute, integrate the symbol and the take-back page as a plugin and, where needed, build the collection option into the checkout; we check every position on smartphone and desktop. For online shops selling electronics and technology, we combine this with energy labels and battery notices so that everything comes from the same data source. You clarify the legal assessment of your case with your legal adviser; we take care of the technical implementation. If you want to know where your shop stands, get in touch with us.