According to art. 3 lit. s of the Act Against Unfair Competition, websites that offer goods or services must contain clear and complete information about the identity and contact address of the offeror, including its electronic mail (in German "elektronische Post"). The provision does not apply to websites that advertise goods or services, but rely on voice telephony or email to conclude an agreement (art. 3(2) Act Against Unfair Competition).

Art. 3 lit. s was introduced a while ago, but so far, there have - to my knowledge - not been any court decisions on the meaning of "electronic mail". Taken literally, it seems to indicate that the website must list at least one email address. But many e-commerce websites instead use contact forms, which make handling large volumes of enquiries easier and are less susceptible to spam (when using appropriate measures).

The Commission on Fairness in Commercial Communication ("Lauterkeitskommission"), a self governing body, had to decide on the interpretation of "electronic mail" when a consumer complained that an e-commerce website contained a contact form, but no email address. It held that the provision of a contact form was sufficient, and the operator of the website had not run afoul of art. 3 lit. s Act Against Unfair Competition. The Lauterkeitskommission is no court, but this decision should at least give some guidance that an email address is not required if there are other, equally convenient, means of contacting the website's operator provided.

Link to the decision (PDF, see page 4).