In this edition, we continue to offer our subscribers specialized information on EPR compliance.
If you have any questions, our experts are available for personal consultation.
Today's topics at a glance
EU: New regulation for sustainable products comes into force
EU: New obligations for Amazon Sellers
Spain: Apply for Tax Id Number (NIF)
Germany: Call for rapid ban on the sale of disposable e-cigarettes
Germany: Changes to the BedGgstV - notification obligation from 1 July
Germany: Standardisation project for e-bike and e-scooter batteries
Latvia: New EPR obligations for textiles
Fresh Up - Reminders / Dates
We hope you enjoy reading the newsletter and look forward to your feedback! Best regards,
Deutsche Recycling
EU: New regulation for sustainable products comes into force
From 18 July 2024, the new EU Ecodesign for Sustainable Products Regulation (ESPR) will come into force, replacing the previous Ecodesign Directive from 2005.
This regulation is intended to set minimum environmental requirements for almost all products that are placed on the market in the EU. The aim is to save energy and raw materials and make the entire life cycle of products more sustainable.
Which products are affected?
While previously only energy-consuming products such as light bulbs, refrigerators and washing machines were regulated, the ESPR now covers almost all products. The focus is particularly on:
Textiles and shoes
Furniture
Iron, steel and aluminium
Detergents and chemicals
Only a few product categories are exempt, such as vehicles and safety-related products. Online trade and imported goods are also covered by the regulation.
New requirements for products
The ESPR brings with it a large number of new requirements that cover the entire life cycle of a product:
Durability and reusability
Upgradability and reparability
Resource efficiency and recyclate content (proportion of recycled material)
Reprocessing and recycling
Maximum levels of substances of concern
Information requirements, such as the CO2 or environmental footprint Digital product passports will be introduced to make this information transparent. Energy consumption labelling will also be supplemented by a reparability index and an ecodesign label.
What do companies need to do now?
Companies should prepare for the new requirements at an early stage. In the coming months, the EU Commission will issue delegated acts that define the specific sustainability aspects. Companies will have a transitional period of 18 months from the entry into force of the respective product regulation to implement it.
If you need support in complying with the new regulation, our experts are available to guide you through this process and ensure that your company fulfils the requirements.
With the new Battery Regulation, sellers who sell batteries or products containing batteries will face new obligations.
Amazon is already informing its sellers through Seller Central that, starting August 18, 2025, extended producer responsibility will apply. Affected sellers should take action now to meet these obligations in time.
What Sellers must do now!
Manufacturers of batteries and products containing batteries must ensure that these products are CE labelled. In addition, retailers who sell affected products must provide evidence of compliance with the due diligence obligations by providing a registration number. In Germany, this requires registration with the EAR Foundation, which manufacturers can already do. In France, Italy, Poland, Sweden and Spain, registration with the relevant authorities is also already possible. Amazon states that it will provide information when registration is possible in other EU countries. The registration number must then be verified in the compliance portal for each member state. According to Amazon, the portal will go online in the third or fourth quarter of this year. In addition, annual battery sales must be reported and environmental fees must be paid to the relevant EU authorities. Amazon will inform its retailers again in the second half of the year about the submission of environmental fees and registration numbers. It is important that affected companies act in time to remain compliant. Our experts are at your disposal to support you in implementing the necessary measures. Click on the button below now to make a free enquiry.
Non-resident companies in Spain must provide a Spanish Tax Identification Number (NIF=Número de Identificación Fiscal). This requirement is an important prerequisite for smooth business operations in Spain.
Deutsche Recycling offers you a full-service packagefor this. You will receive your NIF number with us in no time.
Germany: Call for rapid ban on the sale of disposable e-cigarettes
Disposal and environmental organisations, together with the German Medical Association and other medical associations, are calling for a rapid ban on the sale of disposable e-cigarettes in Germany.
They point out the health hazards, fire risks associated with improper disposal and the waste of resources caused by these disposable products.
The Federal Environment Ministry's current draft amendment to the ElektroG stipulates that all distributors of disposable e-cigarettes must take them back in future, but not until mid-2026. The associations criticise the fact that there is no incentive for consumers to return disposable e-cigarettes, which could lead to continued improper disposal. The signatories see legal points of reference for a ban in Section 4 of the German Electrical and Electronic Equipment Act (ElektroG), which could stipulate requirements for product design, and in Section 24 of the German Closed Substance Cycle and Waste Management Act (Kreislaufwirtschaftsgesetz), which can stipulate requirements for products.
A ban is also possible for reasons of health and youth protection. "There are therefore various legal options available for banning disposable e-cigarettes," the letter states.The associations point out that Belgium has already adopted a ban.
Talk with an Expert
Are you a manufacturer, retailer or distributor of disposable e-cigarettes and have questions regarding the ElektroG?
Do you need support in complying with EU regulations?
We will be happy to help you. Simply get in touch with us via chat, email, contact form or telephone. We will answer your enquiry within the next 24 hours.
Germany: Changes to the BedGgstV - notification obligation from 1 July
A new version of the Consumer Goods Ordinance (BedGgstV) came into force on 1 July 2024. This ordinance now contains a notification requirement for companies that manufacture, handle or place food contact materials and articles on the market. This new regulation affects both stationary trade and online trade.
Affected parties:
Manufacturers: Companies that produce food contact materials and articles as finished products (e.g. packaging industry).
Handlers: Operators of storage facilities for food contact materials and articles.
Distributors: Retailers and others who sell or otherwise distribute these items.
Definition of food contact materials and articles:
Food contact materials are any items that are intended to come into contact or are already in contact with food. Examples of this are
Machines for the production of food.
Objects for the preparation and treatment of food (e.g. meat mincer, coffee grinder).
Food packaging (e.g. cling film, paper bags).
Objects for eating and drinking (e.g. crockery, drinking glasses, cutlery).
Exceptions: Exempt from the obligation to notify are Food business operators who are already registered in accordance with the Food Hygiene Ordinance. Producers who supply small quantities of primary products directly to end consumers or local retail outlets.
Business operators must report the following information to the competent authority:
Name, address and legal form of the business and the responsible operator.
Name and address of the respective business.
Type of activity of the business, including distance selling activities.
Group of materials and articles according to Annex I of Regulation (EC) No. 1935/2004.
Changes: If there are changes in the company or business, such as the discontinuation of the placing on the market of food contact materials or the use of a different type of material, these changes must also be notified to the competent authority. It is important for your company to prepare for the upcoming changes now. Our experts will be happy to assist you if you need support with the BedGgstV. Click on the button below now to make a free enquiry.
Germany: Standardisation project for e-bike and e-scooter batteries
The large number of e-bikes and e-scooters and the different manufacturer standards make it difficult to maintain, replace and upgrade batteries. A lack of standardisation causes problems and inefficiencies.
Standardisation objectives: uniformity and compatibility
The Association of German Electrical Engineers (VDE) and the German Commission for Electrical Engineers (DKE) are launching a project to develop a VDE SPEC. A VDE SPEC is a document that establishes technical requirements and standards. This SPEC aims to establish clear rules for the connection and installation of batteries and battery packs, including precise specifications for connections, labels, and dimensions. The goal is to enhance compatibility and interchangeability of these products, leading to cost savings and environmental conservation. Advantages of standardisation:
Compatibility and interchangeability: rechargeable batteries can be easily exchanged between different models.
Conservation of resources and recyclability: standardised batteries facilitate recycling and environmental protection.
The consortium plans the kick-off in July 2024 and aims to publish the standard within a year. It will involve designers, manufacturers, retailers, logistic companies, recycling firms,and consumers.
This standardization effort aligns with similar initiatives such as the recently mandated unified batteries for DIY tools and the Bundestag-approved standard for universal charging cables for mobile phones and other devices.
Deutsche Recycling offers a Legal Monitoring Service that provides relevant information and supports implementation. Our advisory team is available for any inquiries you may have.
From 1 July 2024, Latvia has introduced extended producer responsibility (EPR) for textiles. Obligated companies, such as producers, importers and online retailers, that place textiles on the Latvian market must now pay a natural resources tax (NRT).
This tax amounts to EUR 0.5 per kilogramme of the products concerned and finances the state disposal of textiles.
Obligations for companies
Companies are obliged to participate in the EPR if they:
manufacture textiles in Latvia.
apply their own brand to products from other manufacturers.
import textiles to Latvia for resale.
sell textiles to end consumers in Latvia via distance selling.
Which products are covered by the EPR in Latvia?
The EPR obligation applies to clothing, footwear and home textiles.
If you need assistance with compliance in Latvia, our experts are available to guide you through this process and ensure your business is compliant. Click the button below now to make a free enquiry and receive assistance.
We cordially invite you to our exclusive webinar "EPR-verplichtingen moeiteloos navigeren" on Thursday, August 1, 2024. In this webinar, our expert Tim Ludwig will specifically address our Dutch-speaking audience and provide valuable information on complying with EPR guidelines in online commerce.
Denmark - EPR packaging: As an obligated company for the EPR in Denmark, you are required to report your planned packaging consumption no later than 30th September 2024.
To ensure that you continue to receive an informative and appealing newsletter in the future, we look forward to your feedback. Please feel free to send us an email with your comments and suggestions for improvement.
.png?upscale=true&width=520&upscale=true&name=%C3%96kodesign%20(1).png)
.jpeg?upscale=true&width=520&upscale=true&name=eBike%20Akku%20wechseln%20und%20recyclen%20(1).jpeg)
-2.png?upscale=true&width=1120&upscale=true&name=EPR%20verplichtingen%20-%20Tim%20Ludwig%20(2)-2.png)
