In general, Deutsche Recycling is a specialist for Europe-wide and worldwide licensing solutions. Regardless of what country you export your products to, we know all applicable environmental regulations and requirements. We are your point of contact and service provider for the optimised licensing of product packaging, waste electrical equipment (WEEE) and batteries, for instance, offering you customised, cross-industry full service. We advise you, analyse the applicable framework conditions, develop a strategy that is ideal for your business and take up operational implementation.
Analysis and strategy
Full licensing service
Provision of authorised representatives in the framework
of the WEEE legislation in the EU
Three directives have been passed in the European Union (EU) up to now that govern the licensing regarding waste disposal and recycling in the context of merchandise export. These directives have been implemented in the national legislation of the Member States – hence there are more than 80 individual regulations in the EU, which must be complied with by merchandise exporters. Worldwide, a large number of other comparable, country-specific laws and regulations apply.
The following constitute the legal implementation in the EU Member States:
European Packaging Directive
European Battery Directive
European WEEE Directive (waste electrical and electronic equipment)
Put simply: Everybody who is legally obligated to do so. Whether your company is obligated can be answered only on a case-by-case basis, because it depends on various factors such as the company and sales structure as well as on the respective country-specific regulations, of course. It can be finally clarified only by means of an individual analysis. This analysis then constitutes the basis for a licensing strategy, which aims at optimising costs.
Everybody putting packaging, electrical equipment and batteries on the market within the European Union must comply with the aforementioned directives, namely in the form of their respective national implementation. In the framework of the superordinate European idea of product responsibility, corresponding licensing regulations are in place in each Member State. They differ from country to country, however – there are more than 80 individual arrangements in the EU.
This depends on the individual case. Again, there are country-specific regulations – the penalties differ from country to country. In some cases, the penalties are quite drastic, e.g. in Germany. Financially, it can mean a sum in the five-digit range. In addition, CEOs are personally liable in some cases. Bans on operating and selling are possible in some countries. Based on an in-depth analysis, we assess the respective risks entailed on an individual basis.
The licensing regulations that apply to you depend on the form in which you operate in the respective country. In order to clarify this, we need various detailed data from you. The customer and sales structure, for example, as well as the sales channels are relevant. It is important, for instance, whether you operate your own branches, supply end customers directly from online shops or collaborate with dealers and importers.
Once we have established what licenses we implement for you operationally, we take up the complete administrative processing and handling – including registration, correspondence, contractual matters, quantity reports, reporting and auditing. All you have to do is report the quantities destined for the respective countries at certain deadlines. We take care of the rest!
Legal monitoring means constant observation of the legislation in our service areas, e.g. WEEE/ElektroG (law that implements the WEEE Directive in Germany), BatterieG (law that implements the Battery Directive in Germany) and the Packaging Ordinance. Through legal monitoring, we keep track of (new) laws for our clients and we know all local obligations in all relevant countries for you as a producer.
This way, we are able to provide you with information on the requirements for access to specific markets as early as in the planning phase. Product-specific and company-specific questions can be clarified (e.g. standards, certifications, labelling obligations).
The National Register for waste electric equipment (stiftung ear) in Germany is the “Clearing House of Producers”, in the meaning of the Electrical and Electronic Equipment Act (ElektroG). Entrusted with sovereign rights by the Federal Environment Agency (UBA), stiftung ear registers the producers of electrical and electronic equipment and coordinates the provision of containers and the pick-up of electrical and electronic waste equipment at the örE (public waste disposal authorities) in the whole of the Federal Republic of Germany.
Representative in Germany (Section 3 No. 10 ElektroG)
Since the amendment of the ElektroG, only those producers (Section 3 No. 9 ElektroG) who are established in Germany can register with stiftung ear. Producers without an establishment in Germany must engage an authorised representative. The representative then applies for the required registrations on behalf of the actual producer. Only a legal person established in Germany can be an authorised representative (cf. Section 3 No. 10 ElektroG).).
Deutsche Recycling is entered in the register of stiftung ear as an authorised representative
Authorised representative in other countries (WEEE Recast 2012)
The international statutes prescribe registration through an authorised representative if the producer/distributor is selling electric/electronic equipment by distance selling to private persons in other EU countries without having an establishment in the country.
Example (Section 8 Paragraph 5 ElektroG 2):
Distance selling dealers established in the Federal Republic of Germany are obligated to engage authorised representatives in other Member States if they deliver directly to end users.
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