Through more transparency, the Czech legislative authority aims for increased awareness and compliance with environmental protection obligations. With the legal act on end-of-life products 542/2020, it was decided to oblige producers to disclose the costs of collection, treatment and environmentally sound disposal (visible fee) in invoices. Although this possibility is explicitly mentioned in Article 14 of the EU Directive 2012/19/EU, the "visible fee" is voluntary in many EU countries and even prohibited others (including Germany).
In the Czech Republic, disclosing of costs was voluntary until 2020. Since 1st January 2021, the legal act 542/2020 has been in force and with it the obligation of the visible fee. The Ministry reasons, as follows:
Even before the new legal act came into force, the possibility of the visible fee was used by some producers, which led to confusion in the market. Buyers were uncertain whether the product had been reported in conformity with the law when invoices did not show disposal costs. Now, the absence of an environmental fee on the invoice is supposed to indicate that the product has not yet been reported in accordance with the requirements of the WEEE Directive. Free riders are thus recognisable at first glance. Commercial buyers, for their part, inevitably become producers acquiring undeclared products and will have to fulfil the corresponding obligations.
In addition, it is intended to create transparency of the disposal prices of the take-back systems. Take-back systems are obliged to offer all their customers the same price for collection, treatment and environmentally sound disposal of electronic equipment.
Last but not least, end-users are to be made aware that separate collection of waste equipment is necessary for the protection of the environment and thus it shall not be disposed in municipal waste.
In the same legal act 542/2020, filament bulbs are no longer excluded from the scope of WEEE-regulations. You therefore have to report filament bulbs in the Czech Republic (unlike in all other EU states) since 01.01.2021.
If you sell products to the Czech Republic or would like to know more about designated disposal costs in the EU, Rebekka Schwarber will be happy to assist you at firstname.lastname@example.org or via +49/40/750687-150.
For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/accumulators and packaged products or packaging, please click here: https://www.take-e-way.com/services/international-compliance/