Germany EPR registration and filing

Extended Producer Responsibility (EPR) system requires producers of certain goods to register with the relevant authorities, ensuring that they take responsibility for the collection, recycling, and disposal of their products after they are used. This system is a part of Germany’s efforts to reduce waste and promote recycling, in line with EU regulations.

Here’s a general outline of the steps for EPR registration and filing in Germany:

Identify if Your Products are Affected by EPR

  • Packaging: Producers or importers of packaging (e.g., plastic, glass, paper) that becomes waste are required to register.
  • Electrical and Electronic Equipment (EEE): Companies that place electronic products on the German market must comply with EPR requirements for their items.
  • Batteries and Accumulators: Manufacturers or importers of batteries and accumulators must ensure their products are registered.
  • Vehicles: If you produce or import motor vehicles, you must register for EPR related to their disposal.

Select a Compliance Scheme

  • Producers can join a compliance scheme (often referred to as an industry collective), which handles the take-back and recycling process. These organizations are responsible for collecting the product waste and ensuring that recycling targets are met. Common compliance schemes in Germany include:
    • Der Grüne Punkt (The Green Dot): For packaging waste.
    • Stiftung Elektro-Altgeräte (Foundation for Electrical Appliances Waste): For electrical waste.
    • Batterieverordnung (Battery Regulation): For batteries.
  • Alternatively, producers can operate their own compliance system, but this is more complex and requires significant effort to ensure compliance with German regulations.

Register with the Central Packaging Register (ZSVR)

  • Packaging Registration: As of 2019, businesses that place packaged products on the market in Germany must register with the Zentrale Stelle Verpackungsregister (ZSVR), the Central Packaging Register. This applies to packaging that will be used by consumers (e.g., retail packaging).
  • To register, producers need to provide information about their company and the types of packaging they are using.

File EPR Reports

  • Annual Reporting: Depending on the product, producers are required to file reports, typically annually, regarding the quantity of products placed on the market and the waste they generate.
  • Packaging: Businesses must report the quantity of packaging they place on the market and the recycling rates achieved. They must also show proof of payments to the chosen compliance scheme.
  • Electrical/Electronic Equipment: The report should contain details about the amount of electrical waste and the proper recycling efforts.
  • Batteries: Similar to packaging and electronics, businesses need to report on the type and amount of batteries they place on the market.

Pay Fees for Waste Collection and Recycling

  • Based on the amount of packaging, electronics, or batteries placed on the market, producers are required to pay a fee to the compliance scheme. The fee goes toward the costs of collection, sorting, recycling, and environmental management.

Comply with Labeling Requirements

  • For packaging, the Green Dot logo is required on most products. This indicates that the company participates in the recycling system.
  • Other products, like electronics or batteries, may need specific symbols or labels to indicate the compliance with take-back schemes and recycling.

Keep Records

  • Maintain comprehensive records of the registration process, reporting, and payments to demonstrate compliance if requested by authorities.

Fines for Non-compliance

  • Failure to register, report, or pay the required fees can lead to penalties, including fines. It’s essential to ensure all processes are followed accurately and on time.

If you are a producer or importer planning to do business in Germany, make sure to comply with these EPR regulations to avoid any legal complications.