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Product Registration under Revised WEEE Rules Launched in Germany

New German rules on the registration of electrical and electronic equipment (EEE) considerably widen the scope of the products which have to be registered. From 15 August 2018 onwards, all EEE falls within the scope of application unless it is explicitly excluded by a statutory exemption.

Hong Kong manufacturers of electrical appliances, but also footwear, textiles and furniture, may be interested in this development, as the newly defined product range equally covers devices such as clothing and furniture with electrical functions, as well as shoes with built-in electronic shock absorption or with lightbulbs. Exceptions are quite narrow, e.g., equipment for use in outer space or equipment where the electronic device can be extracted for reuse, such as bicycle dynamos.

The new rules will apply as of 15 August 2018. The rules are contained in the 2015 revision of Germany‘s Act Governing the Sale, Return and Environmentally Sound Disposal of Electrical and Electronic Equipment (the ElektroG). The ElektroG implements a 2012 revision of the EU's waste electrical and electronic equipment Directive (the WEEE Directive).

The new rules aim at increasing the rate of old appliances and devices to be properly disposed of and recycled. This means that manufacturers and distributors of previously registration-free devices must register and thereby participate in the disposal costs.

For certain products, the registration requirement depends not only on the nature but also on the intended use, which has led to criticism of the new rules. For instance, clothes with integrated Radio Frequency Identification Tags (RFID) used by retailers to prevent theft or to manage their operations are not classified as electronic equipment and do not require registration, which may come as a relief to Hong Kong’s clothing marketers. However, when the RFID tag functionality is aimed at the end-user, as in electronic door locking systems, the tags are covered by the ElektroG and must be registered.

The competent body for registration is the foundation Elektro-Altgeräte Register (the EAR). Manufacturers and distributors affected by the new rules, which will be applicable from 15 August 2018 onwards, can already start registering according to the new rules. The EAR launched registrations on 1 May 2018.

To comply with the WEEE Directive, the new rules reduce the number of EEE categories from currently ten to six, and the 32 device types to 17 device types. Already existing registrations for devices are automatically re-entered under the corresponding, newly defined device type by the EAR. However, manufacturers must check whether, despite this automatic transfer, the registration of further device types may be necessary.

The German Federal Environmental Agency (the Umweltbundesamt, or UBA) announced that it intends to consistently monitor compliance with the new legal requirements.

Members of the industry have criticised the new system for only providing a “superficial simplification” while at the same time causing "an unnecessary, substantial administrative load” on market suppliers.

Content provided by Picture: HKTDC Research
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