Under Law 2939/2001 and Presidential Decree 117, and in compliance with Council Directives 2002/95 “on the restriction of the use of certain hazardous substances in electrical and electronic equipment” and 2002/96 “on waste electrical and electronic equipment” of 27/1/2003, producers and importers of electrical and electronic equipment (EEE) are required either to set up individual alternative management systems or to join an approved collective alternative management system for waste electrical and electronic equipment (WEEE) covering their activity.
On the basis of the proposals submitted, and with the aim of making use of recyclable materials and protecting the environment, the collective alternative management system for waste electrical and electronic equipment “ΑΝΑΚΥΚΛΩΣΗ ΣΥΣΚΕΥΩΝ ΑΝΩΝΥΜΗ ΕΤΑΙΡΕΊΑ” (Appliance Recycling S.A.) was approved by Decision No. 105134 (Government Gazette 905/17.6.2004).
Producers and importers of electrical and electronic equipment (EEE) that have not set up an individual alternative management system are required to join the approved collective system. They must pay, retroactively from 1/7/2004, the recycling fee due on sales made between 1/7/2004 and the date the declaration is submitted, and thereafter monthly, for the sales of the previous month.
The recycling fee is calculated per unit of weight and varies according to product category.
For companies in our sector, which fall into category 5 under the classification in Presidential Decree 117/2004, the recycling fee for luminaires is €672.27 plus 19% VAT, i.e. €800 in total per tonne. For lamps the contribution is calculated per unit and amounts to €0.101 plus 19% VAT, i.e. €0.120 in total per unit.
Following the Joint Ministerial Decision on the “separate itemisation of the alternative management fee on sales invoices for electrical and electronic equipment” (No. 112145, Government Gazette 1916 B, 24/12/2004), which has been in force since its publication in the Government Gazette (24/12/2004), the fee per product unit must be shown as a separate item on sales invoices. The separate itemisation of the fee does not apply to retail sales receipts. The total fee for each item will be calculated according to the weight of the luminaire, as described above, and per unit for lamps. The recycling fee is a charge levied for the benefit of third parties; it is assessed and paid over by the producer or importer of the product and is subject to VAT.
In connection with the above, and following our contacts with representatives of companies in the field, we found that they are dissatisfied both with the obligation to pay the recycling fee retroactively from 1/7/2004 and with the significant increase it adds to product prices for end consumers.
We also found that some companies intend to set up an alternative body to manage waste electrical and electronic equipment, which would handle the products of companies in the sector.
