The updated regulations impact all obligated packaging and WEEE producers in Germany, including those based in the UK that sell in or to the country.
If you sell products abroad, or even just offer them for sale on your website to other countries, here are the changes which may impact your business.
WEEE Open Scope now in force
The updated WEEE regulations came into force on 15 August 2018 and as an obligated producer selling in or to Germany, you must register with Stiftung EAR for each brand you sell, reporting your EEE products into one of six new categories.
It is important to be aware that if you were previously registered with Stiftung EAR, they will automatically transfer all existing registrations into the new categories on 26 October 2018. Be warned that you should review any transfers of your data they have done on your behalf to ensure it is correct, as inevitably some will be based on assumption.
You must remember that you may also have additional registrations for brands or products that were previously unregistered, since they may now fall into scope of one of the six new categories.
We recommend reviewing your German registrations as soon as possible because additional product registrations or changes need to be submitted to Stiftung EAR by 15 November 2018. Ensuring your data is accurate and submitted correctly can take time and is certainly not a task to leave to the last minute.
It is also worth highlighting that selling EEE in Germany without a valid registration is illegal with serious ramifications, including fines and trade bans. This applies to both B2B and B2C producers. Additional helpful guidance can be found here on the Stiftung EAR website.
The bottom line for WEEE producers is to act now. If you require additional guidance or assistance, please contact our team as soon as possible.
New Packaging regime in 2019
Following the introduction of a new Packaging Law which comes into effect on 1 January 2019, all packaging producers must now register at a brand-new central authority called Zentrale Stelle. This new authority will oversee producer registrations, data reporting, audits, dual systems (i.e. packaging compliance schemes), as well as municipal waste collections.
Importantly, as a packaging producer selling in or to Germany, you must register with Zentrale Stelle by 31 December 2018, even if you are already a member of a packaging compliance scheme in Germany. The new online portal LUCID is up and running for pre-registrations now, and you must complete this by the end of 2018.
Unfortunately, third-parties including external consultants such as Ecosurety, are not permitted to register producer companies or submit packaging data to the register. You must either register yourself or appoint a German scheme to act on your behalf. The good news is that registration is user-friendly and relatively simple, and an English language guide can be found towards the bottom of this web page.
Due to the volume of registrations, we strongly recommend that you action this sooner rather than later, certainly well before January 2019. Maximum fines for non-compliance are due to increase to EUR 200,000, providing an extra incentive to be proactive.
If you require any assistance or guidance with your registrations or data reporting in Germany, please contact our team who are ready to help.
International project manager
Katie manages our expert international compliance services to help ensure our members are compliant with recycling legislation overseas. She has a sharp pair of eyes too, having previously qualified not only as a chartered legal executive but also in PRINCE2 and APM project management. When the devil is in the detail, Katie ensures nothing is missed!
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