Importing Cosmetic Fridges to Germany: CE, RoHS, WEEE and Packaging Law (VerpackG) Checklist for Importers

Importing cosmetic fridges into Germany means running four regimes and two German registries, and the mistake most importers make is treating them as one compliance exercise attached to one product. It is not. The compliance route for a cosmetic fridge is decided by three variant choices — thermoelectric or compressor cooling, DC or AC power input, and offline or connected — and every one of those choices changes which directives apply. Get those three right at purchase order stage and the rest is a documentation checklist. Get them wrong and you will discover the gap at the port.

The examples below come from the product range on our cosmetic fridge page, because that range deliberately spans the variants that matter here: 4 L to 26 L thermoelectric units, AC and DC powered versions, a WiFi and Bluetooth app-control version, and separate 20 L and 30 L compressor lines.

This is a practical checklist, not legal advice. Requirements, thresholds and designated bodies change, so confirm the current position with your compliance adviser or the competent authority before you commit to a shipment.

The Three Variant Decisions That Set Your Compliance Path

Before any certificate is discussed, we ask three questions, and they determine everything that follows. In our order of importance, they are cooling technology, power input and connectivity.

Cooling technology. The thermoelectric cosmetic fridges in our range use a semiconductor cooling module and contain no refrigerant at all — one of our 6 L beauty fridges is specified as 100% freon-free, which is a genuine selling point and a genuine compliance simplification. The compressor refrigerator lines in the same catalogue are a different matter for us: they contain refrigerant, so they fall within the EU fluorinated greenhouse gas rules, currently the Fluorinated Greenhouse Gases Regulation (EU) 2024/573.

Power input. This is the one that catches people out, and it caught us out too on our first design review. The Low Voltage Directive applies to equipment rated for 50 V to 1000 V AC and 75 V to 1500 V DC. A cosmetic fridge designed for DC 12 V to 24 V car use therefore sits outside its scope, which surprises most people we brief. Because the appliance falls below the voltage threshold, the external mains adapter becomes a separate product in scope, with its own declaration, and that adapter is what actually reaches the German mains socket. If your unit has AC 100 V to 240 V input built in, the Low Voltage Directive applies to the fridge itself, and that is the version we quote with an in-line adapter.

Connectivity. Our 9 L app-control version connects over WiFi or Bluetooth, and that single feature pulls the Radio Equipment Directive (EU) 2014/53/EU into scope, along with spectrum, electromagnetic compatibility and safety requirements for radio equipment. It also raises a question an insurer will ask us, and it is a good one: what happens to the product if the app service is withdrawn?

A 12 L thermoelectric cosmetic fridge in the standard configuration: DC and AC power input, digital display, no radio module. This is the variant with the simplest compliance path. Adding WiFi to this same product changes the directive set, which is why the variant has to be fixed before the declaration is issued.

CE Marking: Which Directives Actually Apply

We always start from the same point: CE marking is not a quality mark, and it is not something you affix yourself. It is a manufacturer’s declaration that the product meets the essential requirements of every applicable EU directive, supported by a technical file you keep and can produce on demand.

For a thermoelectric cosmetic fridge the baseline set is narrower than importers usually expect, and narrower than we expected at the start. Electromagnetic compatibility under Directive 2014/30/EU applies to essentially all of them, because there is electronics on the board. The Low Voltage Directive applies only where mains input is built in. Radio equipment rules apply only to the connected version. And the General Product Safety Regulation sits alongside all of them, not instead of them.

What we require in the technical file is specific: product description, design and manufacture information, the declarations themselves, test reports, the RoHS restricted-substances declaration, instructions and warnings, and a description of the production process. Because the file is model-specific, a declaration issued for a 6 L DC unit does not legally cover a 12 L AC unit from the same family, even when the electronics are nearly identical.

RoHS: A Declaration Inside the File, Not a Mark on the Product

RoHS is the piece importers most often misunderstand. It is not a certification logo and nothing is stamped on the product. It is a declaration that the equipment complies with the restrictions on hazardous substances, and it belongs in the technical file alongside the other evidence.

The instrument is Directive 2011/65/EU as amended, including the delegated directives that extended the substance list beyond the original electrical and electronic categories. What we need from the factory is a declaration that names the actual production lot or series, not a generic letter saying the materials used are compliant.

Two practical points come out of our own material reviews. First, we ask whether the declaration covers the plastics, the printed circuit board, the wiring harness and the external adapter, because they come from different suppliers and the combination is what you are placing on the market. Second, we ask how the declaration is re-issued when a supplier changes, because a RoHS declaration that quietly refers to a component you no longer buy is worse than no declaration at all.

WEEE and ElektroG: Register Before You Ship, Not After

German electrical waste law puts a registration duty on anyone who distributes electrical and electronic equipment into the German market, and we have seen importers discover this very late, and since July 2022 that duty explicitly extends to distributors and importers rather than only to producers established in Germany.

The registration itself is handled by the designated body for German electrical waste, the EAR Foundation. Registration and the take-back contract that goes with it are separate steps, and the registration number has to be visible on the equipment or on its packaging so that end users can identify it.

The ordering matters because of what we control. As importer we own the artwork and the market placement, so we own the numbering step, and it sits upstream of the print run rather than downstream of it. Retailers and marketplaces will ask for this number before they will list the product, which makes it a commercial dependency as well as a legal one.

VerpackG: the Law That Stops Containers

The German Packaging Act, which replaced the 1998 packaging law in July 2022, is the obligation that most often halts one of our shipments, and it is the one least connected to the product itself.

We see three duties here, and they are frequently confused with one another. Registration happens in the LUCID packaging register run by the central packaging register office, which is where we file ours, and applies to producers and fillers placing more than 30 tonnes of packaging material on the German market per calendar year. System participation means contracting with one of the approved dual systems, because packaging in Germany is financed through a system of shared responsibility rather than through the municipality. Volume reporting is a separate obligation: once you are registered, you report the tonnage of each material category you place on the market, and the categories are defined by material, not by whether the box is yours or the factory’s.

Three details catch importers out, and they caught us out as well. The 30 tonne threshold is measured in packaging material, so a heavy-duty retail carton per unit counts even when the product inside is small. The LUCID registration number has to be communicated onward to your retail customers as part of your own downstream obligations. And registration is not a one-off: the reporting obligation recurs.

None of this is a Chinese-market obligation, and that is the part which surprises our overseas suppliers. It attaches to whoever places the packaged goods on the German market, which in most structures is the importer or the German distributor, not the factory that filled the carton.

GPSR: The Regulation That Changed the Importer’s Job

The General Product Safety Regulation, Regulation (EU) 2023/988, has been applicable since 13 December 2024 and is the change most importers have not yet absorbed into their documents.

It adds three things that land directly on us as importer. Products from outside the EU need a responsible person established in the EU who can be contacted by both authorities and consumers. Products need traceability, meaning the economic operator, product identifier and batch information have to be recoverable. And safety information has to be supplied in the language of the member state where the product is sold, which for Germany means German.

For a cosmetic fridge we find the traceability requirement is easy to over-engineer and easy to under-engineer. You need enough to answer, six months later, which lot a returned unit came from, and you need it without reconstructing it from an email chain. A batch marking scheme agreed with the factory at tooling stage costs almost nothing then and a great deal later.

One specific watch item we now raise with every customer. Product pages frequently describe cosmetic fridges with food-contact or food-grade language, because the same cabinet is sold for storing drinks or medicines. Food contact rules apply when a product is intended for food contact, and an unsubstantiated claim of that kind on a cosmetic appliance is a claim-substantiation issue under the General Product Safety Regulation. Decide what the product is before you decide what you may say about it.

The Pre-Shipment Checklist

Consolidated into one page, this is what we work through with an importer before the first container is booked. The full version, with the step-by-step detail, is in the checklist below.

The pattern in that table is worth noticing: only two rows belong to the factory, and the rest is ours. Everything else is the importer’s work, and most of it has to be finished before the container is booked rather than after it arrives.

Frequently Asked Questions