Revision of the Waste Electronics Law in Germany (ElektroG3)

Revision of the Waste Electronics Law in Germany (ElektroG3)

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One of the currently most debated compliance topics is the new contents of ElektroG3. Published on May 20th, 2021, most new contents are applicable starting January 1st, 2022.

Here are the most important aspects are to look out for:

First, grocery stores have to be wary of new obligations. If they exceed a floor space of 800m² for all goods and regularly offer Electrical and Electronic Equipment (EEE), they too must take back old electronic devices. For them, all communication obligations regarding Waste Electrical and Electronic Equipment (WEEE) will be new.

Before, dealers with a sales area specifically for electrical and electronic equipment of more than 400m² were obliged to take back waste electronics free of charge. Also, they had obligations to inform consumers about various aspects of waste disposal and the possibilities available. In particular, the communication from dealers is essential as customers cannot tell by themselves whether their dealer is offering take-back and, if so, in what format. Moreover, it is almost impossible for an average consumer to know whether a retail establishment has a floor space dedicated to selling EEE of more than 400m² or not. This problem is even more significant when customers buy electronics online. BattG3 now provides clarity in this respect by extending the notification and reporting requirements.

A second significant change represents an explicit extension of take-back obligations to distance-sellers. The previous version of the BattG did not specifically mention take-back duties of items bought online or through other distance-sales channels. The law now clearly includes those vendors among the obligated parties.

Finally, vendors must take back discarded WEEE in a 1:1 exchange provided that a similar appliance has been sold. In a 1:1 exchange, an old electronic item must be accepted in return where an end-consumer purchases a new, similar device with comparable functions. Vendors must do this free of charge and pay for the return shipment. This duty, however, is limited to three device types:

  • Temperature exchange equipment
  • Screens, monitors, and equipment containing screens having a surface greater than 100 cm²
  • Equipment with any external dimension more than 50 centimeters (Large equipment)

In contrast to other informational obligations, the dealer must actively ask the customer whether they want to use the exchange option or not.
RLG’s compliance management solution supports producers and vendors in ensuring environmental compliance, particularly for Extended Producer Responsibility (EPR) obligations, thereby reducing complexity and compliance risks. If the new features are unclear to you, please do not hesitate to contact us.

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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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