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Dec 2019

Germany: Enforcement of Packaging Legislation

On 09, Dec 2019 | In News @en | By Lisa Schmidt

The German Packaging Register (ZSVR) has announced the tightening of the Packaging Law (VerpackG) enforcement.

The Packaging Law has entered into force on 1 January 2019. According to the ZSVR, now the transitional period has ended. Companies that do not fulfil their manufacturer obligations risk receiving a fine of up to € 200,000. Additionally, the authorities can prohibit non-compliant companies from accessing the market.

Against this background, the ZSVR collaborates closely with the responsible enforcement authorities and constantly reports infringements to them. So far, in 2019 fines between € 15,000 to € 25,000 have been imposed.

We will be happy to assist you to meet your producer obligations.

Please contact:


Dec 2019

Russia: Implementation of TR EEU 041/2017 “On Safety of Chemical Products” Starts

On 02, Dec 2019 | In News @en | By Lisa Schmidt

The Technical Regulation of Eurasian Economic Union TR EEU 041/2017 “On Safety of Chemical Products” is not in force yet (planned entry into force 01.06.2021) but some member states are already well on the way to its implementation.

On November 11, the Russian Ministry of Industry and Trade (the authority responsible for the implementation of the Technical Regulation on the national level in Russia) announced the start of the inventory building of chemical substances and mixtures. Note that Russia preferred to revoke its own national REACH legislation (Decree No.1019/2016) and focused on the implementation of the Technical Regulation of Eurasian Economic Union instead.

Manufactures and importers can now submit information on chemical substances and mixtures already placed on the market or planned for the introduction on the market in the Russian Federation to a database hosted on the website of the above indicated Ministry. The collected information will be included in the national part of the Register of Chemical Substances of Eurasian Economic Union. Substances and mixtures recorded in this register will not be considered as new substances and will be exempted from a complex notification procedure requiring the study of the hazardous properties of the substances and compilation of a chemical safety report.

For more information, please feel free to contact us at:


Nov 2019

Germany: Never before have so many products been subject to copyright levies

On 27, Nov 2019 | In Copyright Levies, News @en | By Lisa Schmidt

After alone this year and alone in Germany, two other large product families became taxable through contracts between collecting societies and companies, Smartwatches are now also taxable. Manufacturers and importers have to pay 1.50 euros per unit. The agreement for Smartwatches applies retroactively from 1 January 2019 and at least until the end of 2022. Only then can the amount of levies be renegotiated.

While the scope of taxable products in Germany was manageable for a long time, it has now become inclusive and comprehensive. Germany is one of the countries with levies on reprography equipment, which includes copiers, printers and scanners. In addition, until a few years ago, only some storage media were subject to levies. But intensive negotiations took place so that today, practically all relevant IT devices, all storage media and the entire range of consumer electronics are additionally subject to copyright levies.

Ultimately, the contracting parties have overcome long-standing obstacles to negotiations, the European market is more competitive, companies have more planning security and right holders have more income.

However, many more companies now have more work to do in terms of sales volume reporting. For example, a Smartwatch must first be clearly distinguished from a pure fitness tracker as well as from jewellery and toys in accordance with the product definition in the tariff agreement.

For more information:


Oct 2019

More sustainability for household appliances

On 21, Oct 2019 | In News @en | By Lisa Schmidt

At the beginning of October, the European Commission adopted new ecodesign measures for some product groups, among others electronic displays (including televisions), light sources and external power suppliers. The novelty of this set of ecodesign requirements consists in its valuable contribution to circular economy objectives. Thus, for the first time the ecodesign requirements also cover the matters of products reparability and recyclability. For example, promoting reparability, in practical terms, means increasing the lifespan of the equipment, which can be made possible through increasing the availability of spare parts over longer time periods after the purchase of appliances.

The newly adopted measures (combined with the energy labels adopted in March) are expected to save as much as 167 TWh of energy per year by the year 2030, which in its turn equals to a CO2 reduction of over 46 million tons, possibly saving consumers €150 per year on average.

More information at:


Sep 2019

Germany – The Packaging Register has published Minimum Standard for the Assessment of the Recyclability of Packaging

On 19, Sep 2019 | In News @en | By Lisa Schmidt

In coordination with the German Federal Environment Agency, on 1 September 2019 the Central Packaging Register (ZSVR) has published the minimum standard for the assessment of the recyclability of packaging subject to system participation.

This is in line with the requirements of § 21 (1) VerpackG, which stipulates that schemes are obliged to calculate the participation fees in such a way that incentives are included with respect to environmentally friendly(ier) production of packaging. The aim of the standard is to help provide schemes with a uniform framework for the determination of packaging recyclability.

This standard is expected to be reviewed and updated annually on the basis of technical progress and feedback reports from the schemes; the next update is planned beginning June 2020.

Further information:


Sep 2019

GRS to change Legal Status – Reduction of Costs prospected

On 19, Sep 2019 | In News @en | By Lisa Schmidt

On 28 August 2019, the collective compliance scheme for portable batteries in Germany, Stiftung Gemeinsames Rücknahmesystem Batterien (GRS), has informed their members that they will apply for an approval as a so-called producer-owned battery compliance scheme according to Article 7 of the German Battery Act (BattG).

Currently, the GRS is a collective battery compliance scheme according to Article 6 of the Battery Act and operates as a foundation on a non-profit basis.

Against that background, the GRS is obligated to pay for collection and recycling of all batteries that are collected in public collection points, regardless of whether the producer of the collected batteries is member of GRS or another take-back scheme. This situation has caused financial imbalance between the GRS and the producer-owned battery compliance schemes.

In order to change the situation, the GRS intends to change their legal status. Once the change is implemented, the costs for take-back and recycling will be shared between all producer-owned battery compliance schemes, the load-balance will be calculated on the total volumes collected in Germany and the market share of the schemes.

As this will reduce the financial burden of the GRS, they have announced that they will be able to reduce the contributions of their members and offer competitive prices.

The new battery law that is expected to enter into force in 2022 will implement further improvements regarding the load-balance between the compliance schemes for portable batteries.


Sep 2019

EEU states launching copyright levy systems

On 18, Sep 2019 | In News @en | By Lisa Schmidt

The five member states of the Eurasian Economic Union (EEU) are currently revising and concretizing their copyright regulations. This applies not only to legal provisions, but also to purely organisational issues and has an impact on the copyright levy systems. A harmonisation of the systems in the sense of this community of states is to be expected.

Russia and Kazakhstan have already introduced levies on devices and storage media. The Russian levy system has been established and active for a long time and is very comprehensive. The scope has been revised recently. Remarkably, the list of levied devices names the EEU code, which fulfils a similar function to the EORI number of the European Union. Kazakhstan has only recently revived the inactive levy system with Ordinances 445/2019 and 391/291. Manufacturers and importers are now called upon to register through binding agreements with collecting societies. They will then have to pay for the quantities of MP3/4-capable devices put on the market. Belarus has also established a complete levy system and only revised its Copyright Act in July (216-Z/2019). Among other things, the law now provides for procedural facilitations, which can also support negotiations between authorities and industry on the amount of levies for devices and storage media.

In two other member states of the Union, neither legislation nor practical organisation have yet reached that stage: Armenia and Kyrgyzstan have the right to private copying. In Kyrgyzstan, a copyright levy is also planned to compensate for legal private copying. However, there are still no effective procedural rules for the Kyrgyzpatent authority to assert the claims.

For more information, please contact:


Sep 2019

Meet us at Eurobike in Friedrichshafen and IFA in Berlin

On 03, Sep 2019 | In News @en | By Lisa Schmidt

  • Eurobike in Friedrichshafen: Thursday, 05.09.2019
  • IFA in Berlin: Monday, 09.09.2019 or Tuesday, 10.09.2019

Your contact to us:

+49 7031 43938-0

We look forward to your contact request and a personal meeting.


Aug 2019

German authorities prosecute infringements against German Packaging Law

On 16, Aug 2019 | In News @en | By Lisa Schmidt

In July, the Zentrale Stelle Verpackungsregister (ZSVR) has contacted dozens of thousands of producers that are not fully compliant with the legal requirements of the German Packaging Law (VerpackG).

The most common lacks of compliance relate to:

  • missing registration with packaging register (LUCID)
  • missing system participation (membership with a packaging compliance scheme)
  • outstanding or incomplete volume declarations.

The ZSVR urges the producers to take action to address the deficiencies identified.

If the manufacturers do not remedy the shortcomings in a timely manner, the ZSVR will forward the information to the competent enforcement authorities so that they can examine whether an offence procedure will be initiated.

Furthermore, the ZSVR has announced that it intends to carry out such investigations on a regular basis in the future. In the long term, this should lead to a higher rate of system participation and licensed packaging volumes.

If you have received a letter from the ZSVR or need any assistance regarding packaging compliance in Germany, please contact us:


Jul 2019

ECHA publishes updated Candidate List

On 18, Jul 2019 | In News @en | By Lisa Schmidt

The European Chemicals Agency (ECHA) has published the new REACH Candidate List on July 16, 2019: Four Substances of Very High Concern (SVHC) were added to the list. The Candidate List of substances of very high concern for Authorization now contains 201 substances.

The newly added substances have many different uses. For instance, 2-methoxyethyl acetate is among other things used in various applications as a solvent (e.g. industrial as well as a for resins and different types of gums). TNPP is mainly applied as an antioxidant for polymer stabilization. 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides are used in the processing of fluorinated polymers. Diverse applications of 4-tert-butylphenol include for example production of epoxy resins and due to its specific properties manufacture of flexible plastics.

Link to the ECHA website: