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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