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The current notification procedure for market participation with the UBA will be replaced by a registration procedure with the Stiftung EAR, although a transition period of 1 year will apply to cases of placing on the market already notified under the previous legal situation. This transition period is almost over. Pincvision's Environmental team is capable of taking care of this for you. If you decide to carry out the initial registration yourself, please be sure to do this on time.
The registration with Stiftung EAR is permanent until it is revoked. Important note: if you fail to register while obligated, the penalties are huge. The possible penalties are a fine of up to €100,000, skimming of profits or a complete ban on sales.
Registration with the Stiftung EAR will result in several administrative fees:
- For the manufacturer registration pursuant to § 20 para. 1 sentence 1 or sentence 2 BattG, Stiftung EAR will charge a fee of €141,70 per manufacturer, brand and battery type or per authorized representative, represented manufacturer, brand and battery type.
- The following verification of the manufacturers' system participation required for portable batteries according to § 7 para. 1 sentence 1 BattG entails an additional fee of €22,00 for you.
- For the take-back systems, the completed registration and obligatory participation in a take-back system leads to a need to amend their operating license, in which each manufacturer must be listed. For this amendment of the license further fees of €109,70 are due.
- If a manufacturer decides to switch to another take-back system, the license must be changed again, which in turn leads to fees of the same amount.
What you should do
To be able to make use of the above-mentioned transitional provisions and possibly not having to be registered with Stiftung EAR until January 1, 2022, we strongly recommend that you check your previous notification of market participation registered with the Federal Environment Agency (UBA). If necessary, update it before December 31, 2021. This is also a service Pincvision provides.
Batteries that you sell will continue to be reported with the applicable compliance scheme. This might be something you’ve seen before, as the waste stream of WEEE has a similar dual system structure. You will now have to declare batteries with the authorities, as well as the compliance scheme.
Pincvision for your Extended Producer Responsibility obligations
Please reach out to us in case you have any questions regarding regulatory reporting for Extended Producer Responsibility like WEEE, Batteries & Packaging.
Fill in the form below and one of our colleagues will get in touch with you soon.
Source: GRS Batterien
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