Changes to ElektroG: What consequences do they have for our customers?

As of 15th August 2018, the so-called Open Scope is going to be introduced. This will lead – on the one hand – to a reduction in the number of product categories from ten to six. In addition, all electrical and electronic equipment will have to comply with the ElektroG, including clothing and furniture fitted with electrical features.
 

As a registered company, what do I now have to do in order to comply with the law in 2018?

As a manufacturer or retailer, you should first check your product portfolio to see whether your existing registration is still up-to-date with the legal changes. Take a close look at your product portfolio asking yourself the following questions:

  • Do I need new registrations with stiftung ear for my products?
    • Either because of the expansion of the scope (see Point 1) or
    • because of changes to the product categories (see Point 2)?

Open timeline
 

Expansion of the scope of the ElektroG

Checking whether additional products are considered to be electrical or electronic equipment requiring a registration as of 2018 - Step 1

Companies need to check whether other products from their range now have to comply with the ElektroG as a result of introducing the Open Scope. For example, products like electrically adjustable writing desks or shoes fitted with blinking lights will need to be registered before they can be sold.

Submit new registration applications - Step 2

Submit registration applications for this new electrical and electronic equipment in the appropriate categories. A suitable decision tree may be found here. This will help you assign your products to the new product categories. stiftung ear provides assistance on measuring the dimensions of the equipment (only available in German). Please submit your planned quantities for 2018 so that we can issue a guarantee for the new electrical and electronic equipment. Please remember that registering with stiftung ear can take up to three months. You should therefore begin as soon as possible. Applications for the new categories can be submitted as from 1 May 2018.
 

Reducing the number of product categories

Automatic transfer to new categories – Step 3

The so-called Open Scope means that the number of categories will be reduced from ten to six. In future, equipment will primarily be assigned according to size rather than function. An overview of the new assignments as well as some examples (for products in the B2C area, i.e. products that are used privately or else that could end up in private households) may be found here. Stiftung ear will automatically transfer your products to the new categories.

Checking that electrical and electronic equipment is correctly transferred

Companies need to check whether their products have been assigned to the correct category during the automatic transfer procedure. This may not be the case. To help you with this, stiftung ear has published a decision tree which you can use to determine which new category your electrical and electronic devices ought to be assigned to.

Measuring dimensions of electrical equipment

In order to assign your electrical and electronic equipment to the correct category, you may have to measure its dimensions. For example, you will need to provide information about the length of its sides or its screen size in square centimetres. These are all parameters that used not to be needed when registering equipment. You should therefore add these details to your inventory management system. Stiftung ear has published a set of instructions for taking the measurements (available in German only).

Submitting new registration applications

If your products have ended up in the wrong categories because they were incorrectly assigned by the automatic transfer procedure, you must submit applications for them to be switched to the new categories. If you require additional types of equipment because you sell both large and small toys, for example, you must submit new registration applications. Please remember that registering with stiftung ear can take up to three months. You should therefore begin as soon as possible.


Current status in other countries – Step 4

The open scope with the new categories is also being introduced in other European countries, in line with the WEEE Directive 2012/19/EU. Certain countries, such as Austria, have already implemented these changes. Some European countries do not intend to introduce the Open Scope system until 1 January 2019.

Since the implementation varies from one EU country to the next, manufacturers of electrical and electronic equipment should find out in good time the current situation in the respective countries in which they operate. For example, several subcategories may be introduced as well as changes in the pricing system. It may also be necessary to submit new registrations.
 

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If you have any further questions, please don't hesitate to contact us.

 

As at: April 2018

 

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