Visible Fees

Visible Fees

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Have you heard of visible fees? In some countries, producers subjected to Extended Producer Responsibility (EPR) must make recycling fees for the product or part of the product they have purchased visible to business partners and end-users. But what are precisely visible fees, how should they be communicated, and where are they mandatory?

The meaning of visible fees

The term “visible fees” refers to an obligation borne by producers to display the financial contribution they are paying to the compliance scheme that manages their products at their end-of-life. Thus, the cost for taking back, treating, and disposing of or recycling these products must be displayed separately from the product price. The purpose of showing visible fees is to inform the consumer or business partners that the price paid to purchase a specific product includes costs for recycling.

Are visible fees mandatory for all product types and in all countries?

Visible fees are not restricted to one fraction obligated by EPR but can be related to WEEE, batteries, or packaging. Covered fractions vary from one country to another, as does the way producers must communicate visible fees. Some country-specific regulations make the display mandatory, others voluntary, and others strictly forbid the producer from sharing any costs related to the product recycling or disposal. For example, in the Czech Republic, it is necessary to mark the fees on tax documents by showing them on a separate line on the invoice. On the contrary, sharing this information applicable to batteries is strictly forbidden by Czech law.

How and where to show visible fees?

The EPR regulation comes from EU directives that are transposed in each Member state differently. Therefore, the regulation in this matter is numerous and disparate.  For example, some countries require visible fees to be reported only on tax documents. At the same time, other local regulations demand to display them on the invoice at the point of sale, and others forbid communication about the fees, as seen in the example above.

RLG provides a clear overview of your company’s obligations and the different legal requirements. We are monitoring the EPR-regulation and are alert of changes affecting the fees requirement. Furthermore, products must be accurately categorized before being sold so that the correct costs for disposal and recycling are displayed at the moment of sale. Finally,  RLG provides its customers with an innovative online tool to calculate their products visible fees that companies must communicate to the end-user and business partners.

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Les Griffith - Speakers

Business Development Director
RLGA

Les Griffith is currently the Business Development Director at RLGA and is tasked with expanding the company’s data management offerings for packaging EPR in the Americas. Les has over 30 years of industry experience in Environmental Services, Extended Producer Responsibility and Reverse Distribution. Les has spent these last 30 years working with organizations to develop progressively more sustainable solutions to the management of end-of-life materials. Prior to joining RLG, Les spent eleven years at Covanta most recently serving as the Business Development Director for the Healthcare Solutions division. His group covered North and Central America and specialized in providing a suite of services to healthcare PROs, take-back services to retail pharmacy and law enforcement and environmental services to the healthcare sector and reverse distributors. Prior to Covanta Les spent 10 years at Waste Management Inc. as an Area Manager for their Healthcare Solutions group.

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Andriana Kontovrakis - Speakers

Director of Compliance Services
RLG

Andriana Kontovrakis is the Director of Compliance Services for Reverse Logistics Group’s US team.  She manages a team responsible for ensuring manufacturer and retailer customer compliance with EPR laws for electronics, batteries, packaging, household hazardous wastes, and other consumer products across the US. Along with RLG partner the Household and Commercial Products Association, she is spearheading the development of the Household Product Stewardship Alliance, a stewardship organization forming under the guidelines of Vermont’s HHW EPR law.  Prior to working with RLG, she was a Policy Analyst with the global electronics recycler Sims Lifecycle Solutions where she managed programmatic implementation and customer and supplier accounts for the US EPR compliance unit and the Deputy Director for Waste Prevention for the NYC Department of Sanitation.

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