take-e-way News and Press Releases

A few days ago, in an interview with the waste management association BVSE the Federal Ministry for the Environment (BMU) outlined the planned amendments to the ElektroG3. Are far-reaching changes possibly imminent for the entire retail sector (stationary AND online)? This can certainly be assumed after this interview. We recommend that you take the forthcoming changes seriously and, as a potentially affected party, inform yourself in good time about your obligations.

Since packaging is often an important element of a product, for instances to provide the necessary protection or to comply with hygiene regulations, the search for alternatives when it comes to materials and packaging is not easy for companies. This is why the Bavarian Chambers of Industry and Commerce, in cooperation with the Resource Efficiency Centre of Bavaria (REZ), has developed a guide for companies to give them an initial introduction to the topic. take-e-way endorses the guide from the BIHK and will be pleased to support you with services required for the production of recyclable packaging.

To be on the safe side, we recommend that you check your B2B registration thoroughly once again. Of course, you are welcome to contact take-e-way in this regard. take-e-way will then check as best we can whether the transferred registration is correct or whether there is a need for action.

While so-called “community masks” without the CE mark can be placed on the market, these are not suitable for use in the clinical sector, for instance. However, for medical respiratory masks which are also marketable in the United States of America, Canada, Australia or Japan, Section 11 (1) of the German Medical Devices Act allows the competent authority to issue special permits and, where necessary or applicable, also to declare such masks without CE marks as marketable in Germany.

As of 5 January 2021, notification of articles containing SVHCs is mandatory according to the amendment to EU Directive 2018/851. SVHC stands for “Substances of Very High Concern”. All articles containing more than 0.1% by mass of SVHC substances are subject to compulsory notification. In particular, articles such as CdTe photovoltaic modules are subject to notification due to their product characteristics. Many other electrical and electronic equipment may also be affected, as heavy metal compounds and flame retardants are also included in the SVHC list. Recommendation: Please make timely preparations for such mandatory notification so that you or your suppliers have sufficient lead time until 5 January 2021.

On 20 February 2019 the European Parliament agreed on new limit values for brominated diphenyl ethers, which are used as flame retardants. Polybrominated diphenyl ethers (PBDE), already known through the RoHS Directive, are now newly governed by this resolution, with the limit value being halved, i.e. massively reduced. For decabromdiphenylether (DecaBDE) the RoHS limit value continues to apply to electrical equipment. This affects distributors, importers and manufacturers since the materials of products may only contain a total of 500 mg/kg of BDEs (brominated diphenyl ethers); for decaBDE as a single substance, the limit is 10 mg/kg. Recommendation: The agreement is not yet legally binding. However, please make sure that your suppliers already have products that meet the above requirements.

The provision of breathing masks from manufactories (“community masks”) is possible if certain rules are followed. The decisive factor is the correct labelling of the masks, which must be clearly distinguishable from medical products or personal protective equipment. Affected manufacturers and importers of breathing masks that do not comply with the Medical Products Act must observe the requirements of the Product Safety Act.

The obligation to submit a declaration of completeness only applies if the volume of packaging placed on the market that is subject to the system participation obligation reached one of the three following quantity thresholds in the previous calendar year: 80,000 kg of glass; 50,000 kg of paper, cardboard, carton; 30,000 kg of ferrous metals, aluminium, plastics, beverage cartons, other composites. The 15 May 2020 target date refers to the statutory deadline over which the German Central Packaging Register has no influence.

According to the provisions of Section 15 of the German Battery Act, distributors of automotive and industrial batteries are obliged to submit an annual documentation of their performance review (collection, take-back and recycling) to the German Federal Environment Agency. The performance review must be submitted to the Federal Environment Agency by 30 April 2020.

Between 4 March and 26 March 2020, as many as three general decrees of BAUA (Federal Institute for Occupational Safety and Health) were added, which now grants special approvals for certain hand disinfection formulations. These can now be produced industrially also for normal consumers, without any supply restrictions. Recommendation: In order to avoid supply bottlenecks for the manufacturers listed under the Biocides Ordinance, the current BAUA general decree should be used.