Effective as of August 15th 2005 all electronic devices sold in the EU require a marking identifying the manufacturer and forbidding to dump the device into the general trash. All devices will have to be recycled. And the manufacturers are required to finance the recycling.
So much so good, nice idea and a good step for the environment. But the problem is the implementation of the process. Each and every EU member country has its own laws for the implementation of the recycling. Some did so far not even care to publish the information in anything but their native language.
The only system I know details about as of now is the German system. And that is so bad that it will kick thousands of smaller companies out of the market.
Any manufacturer or importer who sells devices in the German market has to register with an organisation called EAR. The registration is not free...
If you are selling b2c devices you have to register the amount of devices sold per device class (there are 10 classes, IT equipment is one of them). If you sell b2b devices only you first have to convince the registering organisation that it is really b2b, you still have to register and you have to renew every year.
Selling any device in Germany after November 23rd 2005 without being registered can cost a fine up to Euro 50,000.
The really bad part comes if you do b2c (business to consumer) devices. It does not matter who you are actually selling to, it only matters if the devices you sell could be reasonably used in a private household (a magnetic spin tomograph is definitely a b2b device, a mouse or keyboard is not). Then you have to register the amount of goods you are selling in each category (amount means weight of the goods), you have to put down a secured monay reserve for recycling anything you make (approval of your reserve costs Euro 450), and you will have to pay for recycling stuff that is returned by consumers. That includes old stuff that has been sold before the law comes into effect.
Now that does not sound too bad until you go into the details of "paying for recycling". The way this works is that there are state run places that accept waste for recycling. Those places will start to collect electric/electronic waste sorted in five categories. Every time one of the containers (roughly 30 cubic meters) fills up the registration will look up who is due for recycling and then calls you (costs Euro 45) with the information where the container is. You then have no more than 48 hours to have the container picked up, replaced by an empty one, and sending the waste to a certified recycler.
So far the registration refuses to disclose information about how they will treat companies that produce only a fraction of that volume in a year. The only consolation is that if you overachieve in recycling that amount will be credited unlimited. As a small manufacturer that means possibly once you have taken care for a single container you will not be called upon for the next 50 years. Though that does probably not matter much since you are bankrupt.
And that covers just Germany, there are 24 more countries in the EU...
What is this all about?
Moderator: Guido Körber
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All deadlines have passed, all regulation is in effect. So technically the EU common market has ceased to exist for electric and electronic devices. Several companies have given up or reduced their product ranges, many still are ignorant to the new ruling or deliberately ignore what seems so totally illogic. But first sanctions against violators are starting now.
Though the worst is yet to come: EuP and REACH
Though the worst is yet to come: EuP and REACH