Since the last amendment of the Electrical and Electronice Equipment Act (ElektroG = German WEEE conversion), boilers and hot water storage tanks have been mentioned in the law as examples of category 1 “heat exchangers”. A draft bill of the BMUV (Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection) has now provided for a change. Boilers and hot water storage tanks, depending on their size, should again be assigned to categories 4 and 5 (large and small appliances), as they are not heat exchangers by definition. As take-e-way reported, the Environment Committee of Germany’s upper house, the Bundesrat, spoke out against a reclassification, as the current grouping of these devices into the category of heat exchangers was not erroneous or disadvantageous.
According to EAR foundation (German WEEE registration board), the initiative has so far also failed due to the resistance of the Länderkammer. Accordingly: Boilers and hot water tanks belong to the heat exchangers or to collection group 1. According to existing statutory regulations, manufacturers of boilers and water heaters must have a registration for the appliance type “heat exchangers for use in private households” or “heat exchangers for exclusive use in other than private households”. Please check your registrations and submit an appropriate registration application if necessary.
Should this happen to change in the current legislative process, which is about to be concluded, we will of course inform you.
The take-e-way consultancy team will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to firstname.lastname@example.org for any questions you may have on the ElektroG and the EPR rules and will help you with the registration.
Please note: The Electrical and Electronic Equipment Act, the Packaging Act and the Batteries Act are the topics of our panel event “The Future of Product Responsibility” scheduled to be held in Berlin on 8 November 2022. Free participation for customers of take-e-way and trade-e-bility as well as VERE members. Only a few places are still available. Further particulars and registration details are available here.