November 2018 Newsletter
Newsletter: November 2018
WEEE, Batteries and Packaging Year-End Reporting
Now that we are well into Quarter 4, the end-of-year reporting will soon be upon us! At Accerio we try to make reporting as streamlined and low-stress as possible for you, especially given that for many companies it means collating a lot of data under tight deadlines at a busy time of the year.
Those accustomed to reporting monthly or quarterly will be more practiced, however for those who send data only in January here are a few steps and reminders to help make it run as smoothly as possible.
- To avoid a scramble in January when the deadline is imminent, please let us know as soon as possible if there have been any product changes in your inventory since the last reporting period, including new products, or changes to existing ones.
- If you have changed reporting staff over the last year, please let us know so we ensure we send the data request email to the correct person, and to help anyone unfamiliar with what is needed prepare for January reporting
- The new Open Scope categories are now operational (> and < 50cm dimensions) across much of the EU. If you haven’t already provided dimensions of your products please update us with the details as soon as possible, as they will be required for January reporting.
- Many countries will require a report of any take-back or recycling you have done. Often this will be managed by a scheme on your behalf, but we will need to know if you have done any directly, especially for professional WEEE or industrial batteries. Please ensure you are aware of how to get this data.
- Please make authorized signatories aware that some yearly reports will require their signature to finalize reporting, given this is an extra demand on their time in January and February. We will send reports for signature as soon as they are available.
If you would like us to check through your data before the end of the year to ensure that January is as stress-free as possible, please feel free to contact your account manager.
Austria | Household and professional WEEE, Portable batteries, Packaging |
Belgium | Industrial and portable batteries, Packaging |
Canada – British Columbia | Professional WEEE |
Canada – Manitoba | Professional WEEE |
Canada – New Brunswick | Professional WEEE |
Canada – NF and Labrador | Professional WEEE |
Canada – Nova Scotia | Professional WEEE |
Canada – P. Edward Island | Professional WEEE |
Canada – Saskatchewan | Professional WEEE |
Denmark | Household and professional WEEE, Industrial and portable batteries |
Finland | Professional WEEE, Industrial batteries |
France | Professional WEEE, Industrial and portable batteries, Packaging |
Germany | Professional WEEE, Portable batteries, Packaging |
Hungary | Professional WEEE, Industrial and portable batteries, Packaging |
Italy | Household and professional WEEE, Industrial and portable batteries |
Luxembourg | Household and professional WEEE, Industrial and portable batteries |
Netherlands | Household and professional WEEE, Industrial and portable batteries |
Poland | Professional WEEE, Industrial and portable batteries |
Portugal | Household and professional WEEE, Industrial and portable batteries |
Spain | Packaging |
Sweden | Household and professional WEEE, Industrial and portable batteries |
Switzerland | Portable batteries |
Turkey | Household WEEE |
United Kingdom | Household and professional WEEE, Industrial and portable batteries, Packaging |
USA – California | Professional WEEE |
USA – District of Columbia | Household WEEE |
USA – Illinois | Household WEEE |
USA – Maine | Household WEEE, Portable batteries |
USA – Oregon | Household WEEE |
USA – South Carolina | Household WEEE |
USA – Wisconsin | Household WEEE |
Irish Compliance Enforcement
- Placing WEEE or battery registration number on invoices and other business documents
- Informing customers about their recycling options
- Displaying statutory notices
- Providing country specific information on website or product literature
- Adherence to trans-frontier waste shipment legislation
- Additional Retailer and Distributor obligations
- Other country specific WEEE and battery compliance requirements
Germany's New Packaging Law
Did you know that Germany has a new Packaging Act that will come into force January 1, 2019? If you fall into the category of those who need to comply, you need to act now to have your registration in place by the end of year. This will ensure you are properly compliant for when the new law becomes active.
The New German National Packaging Authority, (the Verpackungsregister), has made a great effort to make the process of registering and reporting as simple as possible, and it is free to register. However, it is still an involved exercise taking time to go through all the required steps.
Details of the requirements include:
- All local companies placing packaged products on the market have an obligation to comply.
- There are scenario-specific obligations for some foreign companies selling products with packaging into Germany.
- Online sales from outside Germany to private consumers in Germany will incur packaging obligations.
- There are no minimal amount exclusions for small producers.
- The strongest provisions apply to sales and grouped packaging to private households.
- Sales to business end-users do not require registration, but free take-back of packaging must be provided.
- All packaged goods are in scope – not just packaging for electronics and batteries.
The system of registering and reporting employs the Polluter Pays Principle, thereby ensuring all those placing packaging on the market in Germany support the costs of processing waste packaging. This makes for a fairer market by making it more difficult for free riders to dodge the system.
Significant penalties for non-compliant actors include fines of up to €200,000 and bans on selling any product in Germany! A public register will publish a list of fully compliant companies, which acknowledges the companies doing the right thing by the law and the environment.
The good news is that Accerio can help assess your obligations and guide you through the process, so please contact us and we will be happy to ensure you are fully compliant in time for the deadline. If you would like to learn more, you can start by watching this video about the process.
USA e-waste and Battery Compliance
Is there any e-waste or battery legislation in place in the USA?
The USA has active e-waste and battery compliance regulations in place in 26 of the 50 States of the Union. The approach is quite different to that of the European Union, and it’s not uncommon for companies to be organized with their EU WEEE and battery compliance and unaware that they also may have requirements in the USA.
Who is responsible for complying?
The e-waste laws vary by state, are product focused, and consider what kind of entity the product was sold to as well as where the customer is located when determining compliance obligations. Who has the responsibility to comply is dictated by who manufactured the product, rather than the selling model. Some states only obligate products sold into that state, although there is a trend emerging in changing that to assessing national sales, and in some cases even global sales are considered.
Is all electronic waste in scope?
The type of e-waste in scope varies significantly from one state to the next, although there is a core focus on computers, monitors and associated peripheral products. Obligated battery chemistry varies quite a bit from one state to the next.
What happens if I don’t comply?
States are active in monitoring waste streams to detect products that are not registered for sale, and publish ‘good’ lists of companies registered and ‘bad’ lists of those who are not, and will ban sales of non-registered products. Litigation exposure and fines for non-compliance are expensive, and increasingly states are losing patience with non-compliers and are tightening up practices.
The e-waste and battery compliance environment in the USA is constantly evolving. Over time it is expected that the scope for product and battery chemistries will expand, and that categories of sales will increase to include some of those previously exempted. If you are unsure if your product qualifies for compliance in the USA please contact us today for an assessment, and avoid ending up on the bad do-not-sell list!