New registration obligation for packaging in Spain

The Spanish packaging law obliges producers to register their packaging. Distributors from abroad must also register through an authorised representative if they sell packaged products in Spain.

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Photovoltaic WEEE Service

Photovoltaic modules – WEEE Service for Germany: Electrical and Electronic Equipment Act

Compliance with WEEE, Battery and Packaging Directives for PV modules, inverters, storage systems and packaging in Germany and all of Europe (EU+EFTA)

The Waste Electrical and Electronic Equipment Directive of the European Union (WEEE, 2012/19/EU) was transposed into national law in Germany by the Electrical and Electronic Equipment Act (ElektroG).

The new Electrical and Electronic Equipment Act took effect on 24 October 2015. Photovoltaic modules have since been subject to the scope of application of the Electrical and Electronic Equipment Act, i.e. they are electrical appliances by definition. This means that producers (first-time marketers) of photovoltaic modules have had to be registered under the Electrical and Electronic Equipment Act since 1 February 2016. Registration is required before PV modules are offered or sold in Germany. PV modules that were already packaging placed on the market before that date do not have to be registered subsequently, but in the event of dismantling/disposal they must be treated in line with the requirements of the Electrical and Electronic Equipment Act, and the quantity flows need to be reported to the competent authority, namely the EAR foundation. This also applies in the event of reuse, which is explicitly provided for by the Electrical and Electronic Equipment Act.

Inverters have already been within the the scope of the Electrical and Electronic Act since 2005 and, depending on their edge length, must be registered as small or large appliances and treated and disposed of accordingly, with corresponding reporting obligations.

Storage systems are to be classified as industrial batteries according to the Battery Act (BattG) and registered as such. Purchasers are to be offered free return options, and corresponding quantity balances and evidence are to be submitted to the competent authority (Federal Environment Agency) as regards the quantities disposed of. This service is also carried out by take-e-way on your behalf.
 

take-e-way will assume the complete monitoring, control and reporting for PV modules and inverters for well-known international PV producers / marketers. Since 2016, over 60% of all registered PV modules have been reported to the market and more than 60% of all collections organised.
 

In the field of own take-back activities, take-e-way’s market share exceeds 90%. This market leadership enables take-e-way to provide its customers with the very best service at the best prices available.

WEEE Germany – take-e-way offers the following services under the Electrical and Electronic Equipment Act to obliged producers

  • Provision of the insolvency-proof guarantee through participation in our guarantee system >> 1st-weee-guarantee <<
  • Principal registration with the EAR foundation
  • Deadline monitoring and regular update registration
  • Monthly volume reporting
  • Annual volume reporting
  • Taking over all communication and correspondence with the EAR foundation
  • Fulfilment of all archiving and verification obligations
  • Monitoring of the recycling chain – only certified waste management companies are commissioned
  • Organisation of waste disposal (collection coordination)
  • Issuance of disposal and recycling certificates
  • Issuance of a certificate of WEEE compliance to your customers
  • For producers outside Germany: Provision of an authorised representative
  • Registration of inverters in conformity with the Electrical and Electronic Equipment Act
  • Registration for power storage / storage systems as industrial batteries according to the Battery Act
  • Organisation of the disposal of storage systems

Service Europe – complete handling with regard to the WEEE Battery and Packaging Directives throughout Europe (EU+EFTA)

Since 2016 all EU countries have implemented the Directive regarding PV.

For this reason, producers / marketers of photovoltaic modules usually register in several EU countries at the same time, or require registration in EU and neighbouring countries at different times.

We offer the appropriate framework agreement for this purpose so that producers can adapt their registrations to their international projects and distribution channels at any time.

As we have different national implementations with regard to the 3 EU directives in all countries, take-e-way supports the examination for legal certainty with regard to producer-specific parameters (distribution channels, product allocation, etc.).

If you have any questions regarding registration within the EU and neighbouring countries, please contact our PV expert Michaela Lepke for a consultancy appointment

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