Reporting and information obligations for manufacturers
Reporting and notification obligations pursuant to Section 18 of the Electrical and Electronic Equipment Act / Section 2 of the Act on the Implementation of the Waste Framework Directive
Quantitative target parameters subject to Section 10 (3) and Section 22 (1) of the Electrical and Electronic Equipment Act (German acronym: ElektroG) have to be published by manufacturers (Article 2 of the Implementing Act of the Waste Framework Directive – amendment to the Electrical and Electronic Equipment Act in Section 18)
Article 2 of the Implementing Act of the Waste Water Directive (German acronym: AbfRRL, printed matter 88/20) provides for an amendment to the Electrical and Electronic Equipment Act in Section 18. Accordingly, the status of compliance with the quantitative targets under Section 10 (3) and Section 22 (1) of the Electrical and Electronic Equipment Act haver to be be published annually by manufacturers.
The Ministry for the Environment, Nature Conservation and Nuclear Safety publishes the quantitative targets achieved in Germany and to be submitted to the EU Commission annually on the Ministry’s website. Manufacturers may refer to this publication in order to meet their extended information obligations under Section 18 of the Electrical and Electronic Equipment Act. The very latest publication is available here.
The German WEEE Registration Board “stiftung elektro-altgeräte-register (ear) releases the values determined for the previous year from the annual statistics report of the manufacturers for Germany on this website.
Each manufacturer is required to report to the German WEEE Registration Board “stiftung elektro-altgeräte-register (ear) by 30 April the quantities of waste electrical and electronic equipment collected from primary treatment facilities in the previous calendar year by weight pursuant to Article 22 (3) of the Electrical and Electronic Equipment Act. Moreover, each manufacturer must make the following notifications by 30 April each year:
- the waste equipment taken back by it per type of equipment and category in the calendar year for which no guarantee is required under Section 7 (1) sentence 1 of the Act,
- the waste equipment prepared and recycled by such manufacturer per category in the calendar year for re-use,
- the waste equipment recovered by the manufacturer per category in the relevant calendar year,
- the waste equipment disposed of by the manufacturer per category in the calendar year, and
- the waste equipment exported by the manufacturer per category in a calendar year to countries of the European Union or third countries for treatment.
take-e-way as a service provider is handling the consolidation of these data and information for its clients, the manufacturers. The data transmitted to the German WEEE Registration Board “stiftung elektro-altgeräte-register (ear) is available here:
|Equipment category||Re-use||§ 27, Par. 1, No. 6 material recovery/ recycling||Waste equipment prepared for reuse and recycled||§ 27, Par. 1, No. 7 Recycling (total) "Recycled equipment"||§ 27, Par. 1, No. 8 Removal||§ 27, Par. 1, No. 9 Export|
|Kat. 1 - Heat exchanger||0,07%||81,23%||81,31%||99,33%||0,60%||0,00%|
|Kat. 2 - Visual display units||0,60%||85,68%||86,28%||94,60%||3,01%||0,00%|
|Kat. 3 - Lamps||0,00%||94,10%||94,10%||94,10%||5,90%||0,00%|
|Kat. 3 - Gas discharge lamps||0,00%||94,10%||94,10%||94,10%||5,90%||0,00%|
|Kat. 4 - Large equipment||0,01%||85,58%||85,59%||96,43%||3,53%||0,00%|
|Kat. 5 - Small devices||0,04%||82,68%||82,72%||97,59%||1,82%||0,54%|
|Kat. 6 - Small devices ITT||0,05%||82,44%||82,49%||97,89%||1,90%||0,16%|
Further information obligations according to the Electronic Equipment Act
Separate collection of old equipment
Electrical and electronic equipment that has become waste is called WEEE. Owners of old appliances must take them to a collection point separate from unsorted municipal waste. In particular, old appliances do not belong in household waste, but in special collection and return systems.
Batteries and accumulators
Owners of waste equipment must generally separate spent batteries and accumulators that are not enclosed by the waste equipment from the latter before handing them in at a collection point. This does not apply if the waste equipment is handed in to public waste disposal authorities and separated from other waste equipment for the purpose of preparation for reuse.
Possibilities for the return of old equipment
Owners of old devices from private households can hand them in at the collection points of the public waste management authorities or at the collection points set up by manufacturers or distributors in the sense of the ElektroG. An online directory of the collection and return points can be found here.
Note on waste prevention
According to the provisions of Directive 2008/98/EU on waste and the Directive’s implementation in the legislation of the Member States of the European Union, waste prevention measures are required on principle to take precedence over waste management measures. In the case of electrical and electronic equipment, waste prevention measures include, in particular, prolonging the life of the equipment by repairing defective articles and selling used ones in good working order instead of dispatching them for disposal. Further particulars are available as part of the waste prevention programme of the Federal Government with the participation of the federal states.
Data protection notice
Old devices often contain sensitive personal data. This is particularly true for information and telecommunications technology equipment such as computers and smartphones. In your own interest, please note that each end user is responsible for deleting the data on the old equipment to be disposed of.
Meaning of the symbol "crossed-out dustbin"
The symbol of a crossed-out wheeled garbage can, which is regularly displayed on electrical and electronic equipment, indicates that at the end of its service life the respective equipment must be collected separately from unsorted municipal waste.
Take-back, labelling and information obligations pursuant to the [German] Batteries Act (BattG)
Separate collection of spent batteries
Options for returning batteries and accumulators
Take-back obligation of manufacturers or their authorised representatives
Under Section 5 of the Batteries Act, manufacturers or their authorised representatives are obliged to take back spent portable batteries free of charge that are [generally] taken back by distributors, public waste management authorities and voluntary collection points and to treat and recycle such items. Non-recyclable spent batteries are to be disposed of in accordance with Section 14 of the Batteries Act. This also applies to spent portable batteries that arise during the treatment of waste equipment in accordance with the Electrical and Electronic Equipment Act and during the treatment of end-of-life vehicles in accordance with the provisions of the End-of-Life Vehicles Ordinance.
Manufacturers of automotive and industrial batteries or their authorised representatives are required to ensure free take-back, treatment and recycling by offering, unless otherwise agreed, a reasonable and free-of-charge return option to distributors for spent automotive and industrial batteries taken back by them and the treatment facilities and by recycling the spent batteries taken back.
We have commissioned take-e-way GmbH to organise the acceptance and recycling of our spent industrial batteries by approved and certified specialist disposal companies. It is a matter of course for our company to provide the financial and organisational resources required by law to meet our take-back obligations. You can obtain information on the collection points and key data required for take-back purposes by calling +49-(0)40/ 750 687-0
There is no obligation for distributors or treatment facilities to hand over these spent batteries to producers or their authorised representatives.
Note on waste prevention
According to the provisions of Directive 2008/98/EU on waste and the Directive’s implementation in the legislation of the Member States of the European Union, waste prevention measures are required on principle to take precedence over waste management measures. In the case of spent batteries, prevention measures include, in particular, prolonging their service life by repairing defective articles and selling used ones in good working order instead of dispatching them for disposal. Further particulars are available as part of the Waste prevention programme of the federal government with the participation of the federal states.
Consumers are legally obliged to return spent batteries and accumulators after use and can do so free of charge via the distributor. No waste is the best waste. Opt for batteries and accumulators with a longer service life, and treat them in accordance with our operating instructions. Regular maintenance by trained personnel helps to prevent waste from occurring in the first place. Please also consider reusing spent batteries and accumulators instead of disposing of them, e.g. by including the battery in a second life cycle or by reconditioning it.
Please avoid the generation of waste from spent batteries as far as possible, e.g. by opting for batteries with a longer service life or rechargeable batteries and returning spent batteries to a suitable location rather than littering the public space with carelessly left batteries and accumulators.
Notification and information obligations
Distributors must inform their customers of the following by means of easily visible and legible texts or pictograms placed in the immediate field of vision of the main flow of customers:
• Batteries can be returned free of charge to the point of sale after use.
• The end user is legally obliged to return spent batteries.
• Meaning of the crossed-out dustbin icon and the abbreviations Pb, Hg and Cd.
The following applies to sales of batteries in the mail order trade:
• The information must be indicated in the presentation medium used or enclosed in writing with the consignment of goods.
Recycling rate industrial batteries 2020
Pursuant to § 15 (3) Batteries Act, distributors of industrial batteries must submit annual documentation to the German Environment Agency on take-back and recovery. Manufacturers of industrial batteries or their authorized representatives can jointly submit documentation for several distributors.
The manufacturers and distributors affiliated to take-e-way have achieved a recycling rate of 100 % in the previous year.
Meaning of the crossed-out dustbin icon and the abbreviations Pb, Hg and Cd
At the end of their service life, batteries and accumulators that are no longer usable must not be disposed of in household waste. This is indicated by the crossed-out dustbin icon. The chemical symbols Hg (mercury), Cd (Cadmium) or Pb (lead) which may appear below the crossed-out dustbin icon indicate the substances that the product contains.
Possible impacts of substances contained in batteries on the environment and human health
Batteries and accumulators may contain substances that are harmful to human health or the environment or pose other hazards. In particular, the handling of batteries containing lithium requires particular caution due to various risks involved. By collecting and recycling spent batteries and accumulators separately, you will help to avoid negative effects on human health and the environment.
For any further questions and information please do not hesitate to contact our responsible colleague Johannes Kern: 0049(0) 40/750687-139!