take-e-way News on EPR & Product Compliance

06/21/2021

WEEE Germany: Questionable cover letters in circulation concerning registration under the Electrical and Electronic Equipment Act

On 15 June 2021, the take-e-way consulting department was informed by one of our foreign customers about a questionable e-mail cover letter with the subject “Elektrogeräte Registrierung“ (Electrical equipment registration), which originated from a German company based in Neuss. If you receive a letter regarding the registration of your products and are unsure of the current status, our advisors will be pleased to assist you.

06/14/2021

WEEE Germany: Damages payable due to failure to register under the Electrical and Electronic Equipment Act

Competitors can assert far-reaching claims for information and damages due to missing ElektroG registration. Businesses are therefore well advised to avoid such violations through proper registration.

06/14/2021

Video: The Authorised Representative under the Packaging Act

The new Packaging Act (VerpackG2) is scheduled to take effect in Germany on 3 July 2021. An important amendment is the newly created function of the authorised representative, who can relieve certain manufacturers of many duties. In our latest Compliance Talk, we explain exactly which manufacturers will benefit from the new option in terms of which obligations. The video is available for viewing here (YouTube):

06/14/2021

Italy: Transitional period of environmental labelling obligation for all packaging extended to 1 January 2022

Amendments to Legislative Decree No. 41 of 22 March 2021, the so-called "Decreto Sostegni", were approved during its conversion into law. These amendments include, inter alia, the suspension of the environmental labelling obligation for packaging, as well as the possibility of trading products already placed on the market without the new environmental labelling requirements, until stocks are exhausted.

06/14/2021

Committee launches Supply Chain Bill

According to the Bundestag, the Committee for Labour and Social Affairs approved the federal government’s draft bill for an amended version of the Supply Chain Act on 9 June 2021. The Act is to apply to companies with 3,000 employees starting in 2023 and to companies with 1,000 employees a year later. The organisation Deutsche Umwelthilfe is also calling for independent environmental due diligence requirements to apply to all companies with 250 or more employees and to smaller-scale companies in certain risk sectors.

06/09/2021

Packaging Act: Do you need an Authorised Representative?

If you do not have a branch office in Germany, you can transfer almost all obligations to an Authorised Representative. If you are interested in this services, please contact us as soon as possible so that we can provide you with the necessary information, application forms and our corresponding Business Management Contract in order to already submit your August Report to LUCID.

06/09/2021

Packaging Act: as of 3 July 2021, increased enforcement pressure is likely due to the obligation of online marketplaces

The amended Packaging Act will take effect on 3 July 2021. Key content of the legislative amendment: Online marketplaces and fulfilment service providers will need to verify that manufacturers of packaged goods are registered with the Central Agency Packaging Register and comply with the Packaging Act. If you are affected by the Packaging Act and have not yet fulfilled your associated obligations, you should take action now without any further delay.

06/09/2021

Amendments to the Packaging Act as of 3 July 2021

The Packaging Act (VerpackG) took effect in Germany on 1 January 2019. Already now, about 2 years later, the legislature has introduced amendments to the Packaging Act of relevance to you, which will come into force step by step, taking account of transition periods from 3 July 2021 to 1 January 2029.

06/09/2021

Stichting OPEN allows for non-Dutch producers to report sales to resellers in 2021

On 1st March, we informed you that the new producers’ association Stichting OPEN does not allow for non-Dutch producers to take over the WEEE quantity reporting of their Dutch resellers. Since many different parties requested reconsideration, OPEN has now published a statement.

06/01/2021

European WEEE enforcement (update): Federal Environment Agency initiates proceedings against Internet traders who ship electrical appliances to other EU countries

On 21 May 2021, take-e-way reported on European WEEE enforcement. Solicitor Johannes Richard of the law firm Richard & Kempcke GbR also expressed an opinion on this topic on the website anwalt.de: “The failure to appoint a responsible person or authorised representative is an administrative offence under Section 45 (1) No. 7, (2) of the Electrical and Electronic Equipment Act (ElektroG), liable to a fine of up to €100,000.”

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