The Plain & Simple WEEE & “Elektrogesetz” Compliance Scheme
for PV Modules

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Registration for PV modules required since 2 February 2016!
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THE PROBLEM

What’s WEEE?

Since 2003, the European WEEE Directive [Waste Electrical and Electronic Equipment] governs the putting on the market, the take-back, and the recycling of electrical and electronic equipment [EEE]. It defines the regulatory framework for the specific handling in the different member states of the EU. Due to dependencies of national recovery structures there is no pan-European implementation of the WEEE Directive. Instead, each member state has its own national legislation, requiring an individual Compliance solution per country.

What’s the “Elektrogesetz”?

The “Elektrogesetz” [“ElektroG”] is the German transposition of the WEEE Directive. Following the underlying “Polluter Pays Principle”  it defines an extensive range of requirements and obligations for the producer or the first company that puts EEE onto the German market, above all the full coverage of the recycling costs. The “Stiftung EAR®” is the official Clearing House for Germany. In transposition of the updated WEEE2 Directive the new “ElektroG2” contains important additional regulations on the scope, the categorization of products, and the take-back of WEEE. It came into force on 24 October 2015.

Why are PV modules affected?

The European PV industry didn’t manage to present an own take-back and recycling solution for old modules to the European Commission. Thus, Brussels decided to put PV modules as “electrical equipment” under the scope of the existing WEEE Directive. Due to the complexity and the fragmentation of the different national implementations of the Directive, the efforts for an own solution at producers and importers of such equipment is quite high. Despite various approaches to establish an EU wide take-back system for old PV modules no such “pan-european solution” exists yet. In Germany, producers and importers need to provide a compliance solution for the new “ElektroG2”, consisting of a registration at the German WEEE Clearing House as well as additional obligations.

What needs to be registered?

Product typeExamplesWEEE relevant?
PV modulesMonocrystalline solar modules, Polycrystalline solar modules, Thin film modules, other types of PV modules (semiconductor solar modules, organic solar modules, etc.)Yes, since 1 February 2016 (1)
Equipment with built-in PV modulesCalculators, balances, garden lighting productsYes
PV installation equipmentPower inverters, charging controllers, measuring and control equipmentYes

(1) Also for fixed installation in motor vehicles (e.g. mobile homes) and boats.

Who needs to act?

  • Producers : German manufacturers of EEE,
  • Importers : Resellers importing EEE into Germany and putting them onto the market for the first time,
  • OEM producers: Suppliers which put their own brand on EEE and sell them in Germany,
  • Distance sellers: National and international companies which directly sell EEE to end users in the EU, e.g. over the internet,
  • Dealers: Resellers that offer noncompliant EEE produced by third parties (“Reseller Rule”).

What’s to do

Producers and importers of PV modules need to provide the Compliance of the products along the following three categories, before they may be offered and sold in Germany:

Administrative duties

  • Provision of a financial guarantee for the case of insolvency, together with an external trusteeship
  • Registration of all brands & equipment types at the Clearing House
  • Recurring input declarations
  • Management of the take-back of WEEE

Take-back & recycling

  • Nationwide take-back of WEEE
  • Provision of empty recycling containers
  • Recyling of WEEE along specific thresholds defined by law
  • Documentation of the recycling results
  • Reporting of the statistical data on take-back and recycling to the Clearing House

Product requirements

  • Environmental product design (ecodesign)
  • Labelling and marking of the products
  • Recycling hints for end users

 No Compliance – No Market!

Which fines and sanctions exist?

  • Legal complaints by competitors or other third parties
  • Fines of up to EUR 100000 per individual case
  • Sales ban until the products are compliant
  • Recall of the noncompliant products
  • Skimming of the profits for historical sales
  • Spreading of the risk of the above mentioned sanctions to all resellers which offer or sell noncompliant products [reseller rule]

THE SOLUTION

Ex-PV® – Our one-stop WEEE solution

The complexity and the complicated handling of the German “Elektrogesetz” make WEEE compliance in Germany a significant challenge for producers and other affected companies. An own solution has to satisfy a wide range of requirements and obligations. Normally, there are several different contacts, suppliers, and cost centers involved, resulting in high efforts and costs. In addition, reliable budgeting is near to impossible, due to the bad predictability of the variable costs. Also, errors during the implementation of the WEEE compliance and also the dynamics of the underlying regulations pose a high risk for all involved parties. Ex-PV® provides a one-stop solution for all requirements and obligations resulting from the German “Elektrogesetz”:

Plain & Simple

  • Very simple and unbuerocratic solution
  • One single contact for all obligations!
  • Qualified consulting on product properties and informational requirements
  • For foreign producers and resellers: No registered office, post address or bank account in Germany required
  • Easy solutions for batteries and sales packaging available. Contact us!

Fair & Transparent

  • One total price per product put on the German market!
  • No hidden or unforeseeable costs. Total financial forecast of all WEEE-relevant costs along the sales
  • One single cost center for all efforts!
  • No separate financial guarantee required
  • No capital lockup
  • No “container lottery”

Safe & Compliant

  • Reliable coverage of all requirements and obligations from the German “Elektrogesetz”
  • Germany-wide take-back and recycling of your EEE
  • Thousands of available collection points for WEEE for you and your clients (and their clients)
  • On-site pick-up of large quantities possible
  • Full documentation and proofs for the different parties

Hints

  • Don’t offer PV products in Germany without registration!
    Since 1 February 2016, all relevant PV products (modules, inverters, etc.) need to be registered at the German WEEE Clearing House, before they can be offered for sale.
  • Check your individual obligations!
    We’ll gladly support you, if you need to determine the requirements from German WEEE legislation, but also for other environmental topics such as batteries and packaging.
  • Start preparing your WEEE compliance in time!
    WEEE registration will take some time. Start the implementation ca. 2-3 months before the start of your sales.
  • Remember WEEE compliance in other countries as well!
    If you plan selling your products in other states of the geographical Europe you’ll potentially also be required to provide individual compliance and take-back solutions there. We can gladly provide solutions in other European countries, too.

FAQ

When will I need to register?

Since 1 February 2016, PV modules need to be registered in the appropriate equipment type and in all applicable brand marks, before they may be offered for sale and put on the market. Please note that installation equipment and other accessories are usually already under the scope of the existing legislation and thus to be registered immediately. Please contact us to learn more about your individual obligations.

From the coming into force of the new “ElektroG2”, no new PV modules may be offered for sale or put on the market without registration and compliance with the other requirements of the law. Recyling (of similar modules by other vendors) will usually take place shortly after sales of your own ones. By the way: Under the “Elektrogesetz”, all PV modules will be treated equally in terms of expected lifetime and return rate – independently of the individual composition, quality, and origin!

Currently, not all parts of PV modules can be economically recycled yet. The complex logistics as well as other components as the financial guarantee, fees, and administrative overhead cause additional costs.

Yes. The “Elektrogesetz” won’t allow an exeption to the mandatory participation in the public waste cycle, as no producer may guarantee to take back 100% of their own modules. However, an option for “own take-back” volumes exists.

They won’t. Within a so-called “collection group” all waste modules are regarded equal. Thus, you’ll usually be forced to also recover PV modules by other producers and suppliers instead of your own.

No! Depending on your sales you’ll have to provide separate compliance and take-back-solutions for PV modules and equipment in other countries inside and outside of the European Union (e.g. also Switzerland and Norway). Contact us to learn more about your specific requirements.

Like all other waste related EU Directives the WEEE Directive has been transposed on a national level, i.e. each member state of the European Union features their own legislation and take-back scenario. You may find so-called “pan-European compliance schemes” in the market. However, there is no working European-wide WEEE solution for PV modules yet (and it’s doubtful whether there will ever be any).

CONTACT

Ask for a quote – free of charge and with no obligations

We can gladly offer you a solution for all your requirements from the German “Elektrogesetz”. Please use the following form to contact us, or call us or writen an eMail.

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