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Blog: International Compliance

3rd December 2018

Melanie Harper

If your organisation exports to another country or has a presence overseas, you may need to comply with environmental legislation. Whether it be Packaging, Batteries or WEEE, producer responsibility regulations span across Europe.

The producer responsibility directives aim to reduce the environmental impact of waste through an increase in recovery and recycling. Each member state is set targets which feed into broader EU objectives. Producers are required to provide accurate and reliable data to the relevant authority of each member state, picking up a financial obligation based on the data submitted.

EU Directive on Packaging and Packaging Waste

Packaging is defined as 'all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from the producer to the user or the consumer'. This covers primary, secondary and transit packaging.

EU Directive on Batteries

This distinguishes between portable, industrial and automotive batteries with all battery types within each category in scope regardless of shape, volume, weight, material composition or intended use.

EU Directive on WEEE (Waste Electric and Electronic Equipment)

The Directive applies to all producers irrespective of selling method with distance sellers required to appoint an authorised representative in the member state in which they sell.

Are you Affected?

Environmental regulations cover all EU member states. Broader EU Directives are interpreted by each member state and legislation written into law. Comply Direct can help with France, Ireland, Germany and Italy.

Are you Obligated?

There is no single European-wide registration and very little standardization in registration, data and reporting requirements. Producers are instead required to register within each country in which they are obligated. Generally, a physical presence within a country is required for packaging producers to be obligated. However, it is not uncommon for customers overseas to demand a fully licensed and registered product pushing the cost of compliance back to UK suppliers.

For WEEE and Batteries, producers selling to end users via distance communication are required to register under national legislation and appoint an authorised representative. Authorised reprensatitives are persons or entities established within member states appointed by written mandate by produces in another member state to fulfil obligations within that territory. If you're selling to distributors, it should be the distributors as the national importers who pick up the obligation. It is, however, worth checking the agreements in place with your customers.

The Obligation Checklist

  • Thresholds; Registration thresholds vary between countries.
  • Product categories; For WEEE producers, the classification of products is different in the UK and overseas. In the UK, we have 14 categories, whilst most European countries have just 10. Furthermore, you need to check whether a product is classed as B2C or B2B and verify that it is in scope.
  • Data; data required differs between countries, particularly with regards to packaging. WEEE and batteries producers report similar data to in the UK. Depending on the country, data submission formats may vary.
  • Green Dot Symbol; This is a packaging symbol of two intertwining arrows. It is not mandatory in all European countries, but if used a licence is required. Green Dot licencing is often bundled into packaging compliance. If your customers are asking for the Green to be printed on packaging, it is worth checking any agreements you have in place with regards to compliance.

How can Comply Direct help?

There are country-specific environmental laws within Europe and many compliance schemes and take back systems. Comply Direct work with a number of partners in France, Ireland, Germany and Italy, picking and choosing those which offer the best value. We assess the market and select the best solution tailored to your business.

Tailor-Made Solutions

Comply Direct are here to meet your compliance needs with a bespoke service designed for you. From an initial review of obligations to registration management, we are here to simplify the process for you.

Get in touch with our dedicated international team today and see how we can help you with your international compliance in France, Ireland, Germany and Italy.

International Compliance

Export to another country or have presence overseas?

You may need to comply with environmental legislation in that country...