Disposing of IT as a business: duties under ElektroG and GDPR
Separate collection, batteries, data erasure and proof – what businesses need to observe.
In short: Retired IT does not belong in general waste. In Germany, businesses must collect old devices separately and have them recycled properly, remove loose batteries beforehand and erase personal data before handing devices over. The proof for this is the pickup receipt, the erasure certificate and the disposal certificate.
What the ElektroG requires
- Separate collection: end users must collect old devices separately from unsorted municipal waste (§ 10(1) ElektroG).
- Removing batteries: waste batteries and accumulators that are not enclosed by the device must be removed before handover (§ 10(1) ElektroG).
- Data erasure: end users themselves are responsible for deleting personal data on old devices.
- Take-back: manufacturers must offer a reasonable way to return devices from commercial use (§ 19 ElektroG). Many businesses instead hire a service provider that handles pickup, data erasure and recycling in one go.
What the GDPR requires
Personal data must be protected by appropriate technical and organisational measures (Art. 5(1)(f) and Art. 32 GDPR) and erased once it is no longer needed (Art. 17 GDPR). As the controller, you must be able to demonstrate compliance (Art. 5(2) GDPR). For IT disposal this means: every erasure and every destruction should be documented – device by device.
Checklist for IT disposal
- List the devices. A list or a few photos are enough for the service provider to calculate in advance and plan the right vehicle.
- Erase or destroy? Working drives are erased with certified software; defective or locked drives are physically destroyed. More on the difference
- Remove loose batteries and accumulators. Batteries built into the device can stay in.
- Have valuable devices assessed. Recent business devices are often still worth money. Which ones pay off
- Release the devices. Release devices from mobile device management or Apple Business Manager before pickup – otherwise a complete inspection is not possible.
- File the proof. The pickup receipt, erasure certificates and disposal certificate belong in your records.
The proof you receive
| Document | When | What it proves |
|---|---|---|
| Pickup receipt | at handover | which devices were handed over and counted; you keep a copy |
| Erasure certificate | for every erasure | device, drive, serial number, erasure method and time |
| Disposal certificate | on completion | client, date, devices with quantities, proper disposal and material recycling under ElektroG and KrWG; destroyed drives listed separately |
What we take care of
We collect free of charge in Berlin and Brandenburg – from single laptops to complete server rooms –, erase or destroy the drives, buy valuable devices and send the rest for proper recycling. We work exclusively for businesses, public authorities and institutions.
More on our services: IT recycling · Server disposal · IT buyback
Sources
The regulations cited, in their official wording:
- § 10 ElektroG – separate collection (German)
- § 19 ElektroG – take-back by manufacturers (German)
- General Data Protection Regulation (GDPR), EUR-Lex
- Art. 32 GDPR – Security of processing
- Circular Economy Act (KrWG), official German text
Frequently asked questions
Who is responsible for data erasure?
Under the ElektroG, the end users themselves – that is, your company. We carry out the erasure and give you an erasure certificate for every erasure as proof.
What happens to batteries and accumulators?
Loose batteries and accumulators must be removed before handover; we do not accept them, including spare batteries from UPS systems. Batteries built into a device are not a problem.
Is pickup free of charge?
Yes, we collect free of charge in Berlin and Brandenburg, and nationwide on request.