The VERE e.V. association has received a draft bill from the BMUV (Federal Environment Ministry) for an ElektroGBattGGebV ordinance for the reference year 2023. This ordinance sets out the fees to be paid by registered producers to the EAR Foundation (German WEEE & battery registration board). The fees are reviewed every year to ensure that they are up to date and the fee items are adjusted to the respective current total cost calculation and forecast case numbers (in particular registrations) of the EAR Foundation.
What is particularly noteworthy about the eighth ElektroGBattGGebV is the introduction of a quarterly fee for registration account holders of €24.10 per quarter. This fee element is a novelty and has the following characteristics:
- the fee is independent of quantity,
- the fee does not relate to a specifically named process (e.g. registration or warranty check),
- the fee is levied permanently during the registration period of a manufacturer, irrespective of a cause-related effort,
- the fee includes both B2C and B2B registrations.
Due to the fact that the new fee is not dependent on quantity, it places a particularly high burden on small and medium-sized enterprises (SMEs) in relation to the sales volume. VERE e.V. has strongly criticised this in a statement to the BMUV.
According to the last draft status known to us, annual fees must now also be paid for B2B registrations, as the quarterly fee to be paid does not make any distinction between B2C and B2B registrations. Previously, B2B registrations were entirely exempt from ongoing fees.
The quarterly fee only affects registrations of electrical and electronic equipment; battery registrations are not affected.
According to information from the circles involved, no changes to the content of the draft ElektroGBattGGebV available to VERE are expected. We will keep you updated in this regard.
The take-e-way consultancy team will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to beratung@take-e-way.de for any questions you may have on the Electrical and Electronic Equipment Act and the EPR rules; the team will help you with the registration.
