Berlin/Hamburg/Fürth (Germany) – On December 14th, 2011, the Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit (BMU) (=The Federal Ministry for Environment, Conservation and Nuclear Safety) has enacted the fourth regulation to modify the ElektroGKostV (= The Cost Ordinance on the Electrical and Electronic Equipment Act – ElektroG). This fourth regulation was announced on December 30th, 2011 and came into force on December 31st, 2011. With the new regulation, the fees of the Stiftung Elektro-Altgeräte Register (Foundation EAR) will be reduced at an average of 15 to 18 percent. For comparison: The EAR fee for the basic registration including warranty check (fee-rated matter No 1.01 and 1.04.b) will now cost a total of 182.00 euros (formerly 218.00 euros) and has thus been reduced by 36.00 euros. The repeated reduction of the rates of charges is welcomed by take-e-way and the VERE Association and is valued as another step in the right direction.
However, take-e-way and VERE consider that the relation among the individual rates of charges might have a tendency to adversary effects on small and medium sized companies (SMEs). Thus, the relatively high fees for the basic registration including the guarantee review (fee-rated matters No 1.01, 1.04.a, 1.04.b and 1.04.f) represent a considerable financial obstacle for small suppliers or when selling smaller quantities, whereas the fees for e.g. disposal orders are in contrast considerably lower and thus prove to be an advantage for those suppliers, who burden the system with larger quantities. Precisely the high entry fees often prevent small companies from behaving in conformity with the ElektroG (free-riders) – to the disadvantage of all manufacturers acting in compliance with the law.
The VERE Association already pointed out this problem in advance. VERE holds the view that a load-oriented fee structure would be suitable for all market participants. Therefore, VERE and take-e-way will commit themselves further on towards an equitable treatment of the SMEs.
Below you can download the text of the regulation, the draft of the current regulation as well as the corresponding justification of the BMU. Please contact us if you need an overview of the actual fees of the Cost Ordinance on the Electrical and Electronic Equipment Act in english language. Of course, the team of VERE will be at your entire disposal for any further questions under the phone number +49/40/219010-64 or under firstname.lastname@example.org.