ElektroG 2018: Stiftung EAR clarifies when accessories and spare parts for vehicles need to be registered

This year, the Open Scope means that new products are now covered by the ElektroG and therefore need to be registered with stiftung ear. Stiftung ear has issued a statement on whether accessories and spare parts for vehicles fall within the Open Scope of the ElektroG.

Up until now, vehicles have been exempt from the ElektroG (cf. §2 Para. 2 Item 7). This is not always true in the case of accessories and spare parts. Stiftung ear distinguishes between three cases:
 

  1. If the product and of the vehicle constitute a functional unit, the product does not need to be registered. Being a functional unit means that “the product that has been or is to be installed is necessary in order to use the vehicle”. An example of this is the indicator unit.
     
  2. If the product is not necessary in order to use the vehicle – in other words, if it is an accessory – but at the same time is permanently installed in the vehicle, then the product is not covered by the ElektroG. In this case, permanently installed means that removing it would require an unreasonable amount of effort. This category includes seat heaters that are integrated in the actual seat, for example, navigation systems that are fully integrated in the car, and rear view cameras that are integrated in the rear bumper.
     
  3.  If the accessory …

                     … is not installed in the vehicle.
                     … is only attached to a particular vehicle for temporary use.
                     … can be used universally in different vehicles, or
                     … can be installed and removed again at any time,
          then the ElektroG applies and these products must be registered with stiftung ear.

If you would like to register accessories, please contact us.

Further information about the Open Scope in Germany: