There is a "quarterly fee for registration account holders" (ElektroG) of 24.10 euros per year (approx. 100 euros per year). This fee has been newly introduced. It applies not only to B2C manufacturers, but also to B2B manufacturers. The latter are thus charged with regular follow-up fees for the first time after their initial registration. There is no such fee for BattG-registered manufacturers.
The registration fee (ElektroG) has been roughly halved and now amounts to 12.40 euros per new registration. On the other hand, the registration fee (BattG) was almost doubled - to 29.20 euros.
The fee for appointing an authorized representative (ElektroG) is increased by about four times, while the flat rate for changes is halved.
The fee for the inspection of own returns (ElektroG) is now a fixed 109.70 euros and is no longer variable.
The maximum fee for a determination request (ElektroG) has been reduced from over 3,000 euros to a maximum of 2,000 euros.
The new quarterly fee will certainly lead to queries. It places a heavier burden on small manufacturers and B2B manufacturers in particular - especially since the small hardship application (based on annual sales volumes) has been dropped. The large hardship application also does not provide for an exemption from the quarterly fee 1.2. The fact that the fee is only charged for the Electrical and Electronic Equipment Act, but not for the Battery Act, could raise additional questions. The ElektroGBattGGebV will go into effect on January 1, 2023.
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