WEEE requirements in Germany

Registration timescale

1 June to 24 November 2005

Registration agency

The Elektro-Altgeräte Register (EAR) Foundation is the National Clearing House and received governmental responsibilities from the Federal Environmental Agency (Umweltbundesamt) as the Competent Authority upon authority decision on July 6, 2005

Elektro-Altgeräte Register(EAR) Foundation

Collection and recycling obligations for B2B WEEE

The EC Waste Electrical and Electronic Equipment (WEEE) Directive was implemented in Germany as the ElektroG Act. All producers of electrical and electronic equipment in Germany were required to register with the Elektro-Altgeräte Register (EAR) by 24 November 2005. Producers who are not registered with the EAR are prohibited from putting EEE on the market in Germany. In February, the federal authorities revealed 4,225 producers had registered.

The next deadline that producers of business products must meet is to provide collection and recycling of WEEE arising from new product sales from 23 March 2006. The EAR will contact business producers to ask what collection and recycling arrangements they have put in place in Germany.

WEEE collection and recycling for business products (known as business-to-business or B2B) is fundamentally different from collection and recycling of household products (known as business-to-consumer or B2C). Producers of B2C products are required to finance collection and recycling of household WEEE deposited at local collection facilities (e.g. civic amenity centres and high street retailers). In Germany and most other Member States, the quantity of WEEE that each B2C producer is required to collect and recycle from these local collection facilities is calculated based on their market share of new product sales. In practical terms, B2C producers do not have any option but to join a compliance scheme in each Member State. The compliance scheme will organize collections of WEEE from civic amenity sites on behalf of all its member companies.

For producers of B2B products, the situation is quite different. In Germany and almost all other Member States, business WEEE can not be deposited at civic amenity sites or other collection facilities for household WEEE. Instead, the B2B producer must provide arrangements for the WEEE to be collected from the business end-user’s premises by a licensed waste carrier and taken to a licensed WEEE recycler.

Article 10 (2) of ElektroG requires producers of B2B products ‘to provide a reasonable option for the return and recycling of WEEE’. Most B2B WEEE compliance schemes and recyclers are keen to quote for collection of B2B WEEE from the business end-user’s premises because it is an opportunity for them to generate additional revenue. However, in most Member States conventional logistics companies have the necessary waste carrier licenses and are very well suited to collect WEEE from business end-users. In this case, involving a third party such as a B2B WEEE compliance scheme or a recycler to arrange collections from business end-users can simply increase administrative costs.

Regulations in English Regulations in German

For further information, please contact Aidan Turnbull
Head of WEEE, RoHS & EcoDesign on +44 (0)1225 748420