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Subject Report Updated: Product Take Back in Germany

November 2, 2008

Germany - Product Take-Back

Germany has implemented the WEEE and RoHS Directives through the Electronic Apparatus Act (Law regarding the Placing on the Market, the Take Back and the Environmentally Compatible Treatment of Electronics and Electrical Goods - Gesetz über das Inverkehrbringen, die Rücknahme und die umweltverträg-liche Entsorgung von Elektro- und Elektronikgeräten, or EEE Law). The EEE Law entered into force on 13 August 2005. Note, however, that producers' obligations to take back WEEE do not begin in full until 24 March 2006. Producers are required to register before putting electronic products on the German market. When registering for household electronics, they are required to provide a guarantee to ensure the financing of the proper disposal of electrical and electronic equipment (EEE) placed on the market after 13 August 2005, if such EEE can be used in private households. This registration and guarantee obligation is aimed at preventing producers from placing equipment on the market in an anti-competitive way without living up their take-back and disposal obligations ("free-riders"). Producers are also required to mark their products.



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