Germany WEEE legislative Changes
by Emma Mundy at 13:01 in Environmental, WEEE
As with other EU countries, on 15 August numerous legislative changes to the German WEEE Act ElektroG will come into force. This blog aims to inform you of the changes and if you need to act. From 15 August 2018 Open Scope will be applicable in Germany under ElektroG, from this time all electrical and electronic equipment will fall into scope of the WEEE legislation unless they are specifically excluded by way of one of the exemptions. It is important that you confirm if any electrical equipment should be registered or not under the new scope as it is a legal requirement to register with Stiftung EAR before placing any EEE onto the market in Germany.
Registration
Under the EU WEEE Directive comes changes to the types of categories equipment is to be reported into. 10 previous WEEE categories become 6, with countries being able to implement their own sub-categories. The consequence in Germany is that new applications for registration will need to be made for the new equipment categories. If you bring products onto the German market for the first time from August 2018 then you can apply for the registration under the new scope from 1 May 2018. Existing registrations will be transferred to the new category from 26 October 2018 but you are responsible for checking the registration is correct and informing Stiftung EAR if it needs to be changed, EAR will change the equipment type accordingly after consultation with the producer. Producers have until 31 December 2018 to ensure that their products are registered in the correct categories. Registration of EEE in Germany can be a lengthy process so ensure you are registered in the correct category within plenty of time. By 31 December 2018 you must have the correct registration, therefore any work will need to be done in advance of this date to ensure that the registration is completed in time. From this time it is no longer mandatory to attach an equipment image and description, this is now optional, unless you cannot clearly determine the device type.
New categories
In Germany the 6 new categories have been introduced with 17 sub categories.
Category 1: Temperature Exchange Equipment
Category 2: Screens, monitors and equipment containing screens having a surface greater than 100cm2
Category 3: Lamps
Category 4: Large Equipment (any external dimension more than 50cm)
Category 5: Small equipment (no external dimension more than 50cm)
Category 6: Small IT and telecommunication equipment (no external dimension more than 50cm)
The six new categories are effective from 15 August 2018 but the introduction of new collection groups only applies from 1 December 2018. Therefore, the monthly report for new types of equipment is effective from September.
Registration transfer
A table of examples can be found below whereby the current device types will clearly be transferred to the new device types on 26 October 2018.
For the full list of registration transfers please see here.
Be prepared
Scoping changes will affect all WEEE submissions throughout the EU over the next year. Some countries such as Finland have already implemented their scope changes, others are expected on the deadline of 15 August 2018 and others delayed until January 2019. This means that it is not possible to prepare for all country submissions currently as details have not been released on the scoping changes by all EU member states.
If you need any help on your obligations, registration and reporting in Germany or elsewhere please get in touch here.
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