by Jordan Girling, January 1st, 2016
Jordan is EC4P’s EU Compliance Team Lead where he helps companies identify their legal exposure to WEEE, Batteries and Packaging legislation and provides cost-effective and legally-robust recommendations for compliance.
A new Slovak Waste Act (79/2015) has introduced the obligation for producers of consumer electrical and electronic equipment (EEE) to display the costs associated to the recycling of their products. This Waste Act was published in March 2015; however, the obligations for producers to display the Visible Recycling Fee has only been mandatory since 1 January 2016.
This requirement is only mandatory for producers of consumer products (B2C; Business-to-Business); producers of professional-use products (B2B; Business-to-Business) are not required to display the Recycling Fee. Any retailers associated to the sale of B2C equipment are also required to display the Recycling Fee. The fee can be displayed on a product label, on the packaging of the product or on documentation that is provided with the product at the point of sale.
The Recycling Fee must be displayed on a per unit basis and must not exceed the best estimate of the actual costs associated to the collection, transportation and recycling of the waste product at its end-of-life. In addition, the Recycling Fee cannot include any costs associated to the collection, transportation and recycling of any batteries contained within the product.
In Slovakia, producers of B2C products typical use a local WEEE compliance scheme to provide for the collection, transportation and recycling of their products at their end-of-life. Particular WEEE compliance schemes in Slovakia charge recycling fees on a per unit basis; members of these WEEE compliance schemes can use the fees associated to their product categories as the Recycling Fee and display this fee to the consumer end-user. This will enable to producer to be compliant with this provision of the Slovak 79/2015 Waste Act.
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