WEEE registration obligations of charging stations & wallboxes in Germany and international
It is hard to imagine the streets without them: electric vehicles. A completely new infrastructure must be created around battery-powered vehicles. Other questions are: What happens to the components such as charging stations, devices, wallboxes and charging cables when they are no longer needed? Who takes care of their proper disposal?
The „Stiftung EAR“ informed that e-charging stations are also subject to registration. Accordingly, quantity reports must also be submitted for these and an insolvency-proof guarantee must be deposited. The Federal Council has approved the „building and electromobility infrastructure act“ (GEIG). This regulates the construction of a building-integrated charging and line infrastructure for electromobility. This means that buildings with parking spaces must be equipped with the infrastructure for charging stations in the future.
E-mobility and thus the expansion of the infrastructure is also on the rise internationally. So far, however, there is no uniform regulation on registration and quantity reporting in the EU and worldwide.
Electric car charging stations must be registered as electrical appliances
The “Stiftung EAR” (Foundation for registration of electrical and old appliances), which was entrusted with the implementation of the WEEE Directive by the Federal Environmental Agency in Germany, has announced that all electric charging stations for (commercial and private) electromobility fall within the scope of the German Electrical and Electronic Equipment Act. This means that the extended producer responsibility (EPR) also applies to the distributors of these electric car charging stations.
Due to their size, charging stations for electrical appliances are usually classified in the category of large appliances and must be registered accordingly with “Stiftung EAR”. In Germany, permanently installed charging cables count as part of the entire charging station. Mobile charging cables that can be transported in a vehicle must be registered separately with the “Stiftung EAR“.
If the appliances are registered, annual quantity reports must be made and an insolvency-proof guarantee must be deposited. In addition, you must also explain to the “Stiftung EAR” in a credible manner why your devices are used exclusively in professional business environments other than private households or are typically used in private households.
In many EU countries, charging points also fall within the scope of national WEEE legislation. More on this later in the text.
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Strong increase in electromobility
Electric vehicles such as electric cars, scooters and e-bikes are currently ubiquitous. The Corona pandemic has caused sales of e-bikes to soar, and the fight against climate change has led to a massive increase in the number of e-cars sold. Especially e-cars are causing a steady increase in demand for electric charging stations in Europe.
According to the charging station register of Germanys Federal Network Agency, there are 34,029 public charging points for electric vehicles in this country. This information comes from a reply by the Federal Government (19/26303) to an inquiery by the political party FDP (19/25970).
The number of private car charging stations of building tenants and owners will also increase
In the past, it was not easy or even possible for tenants or owners to have a charging station installed at their own underground parking space. This has changed with the entry into force of the Act to Promote Electromobility and Modernise the Condominium Act and to Amend the Regulations on Costs and Land Register Law.
This provides that every condominium owner can demand permission for the installation of a electric car charging device in the underground garage or in his or her parking space on the grounds of the condominium. An amendment to the tenancy law also ensures that tenants will have an easier time enforcing the installation of a wallbox charger in the future.
Registration obligation: what applies to private car charging stations?
While public charging stations must be registered as B2B devices, this does not apply to those used by private individuals. These must be registered as B2C devices, which entails other requirements regarding the reporting of quantities of goods placed in the market building electromobility infrastructure.
For private car charging stations, unlike B2B devices, a monthly quantity report must be submitted by the 15th day of the following month.
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Gebäude-Elektromobilitätsinfrastruktur-Gesetz (GEIG)
The German government’s plan shows why it is important to regulate the disposal of the components of the electromobility infrastructure. On 11 February 2021, it passed the „Gebäude-Elektromobilitätsinfrastruktur-Gesetz“ (building and electromobility infrastructure act). On 5 March 2021, the law was approved with the aim of accelerating the expansion of charging infrastructure for electromobility in buildings.
The law stipulates that every third parking space in new non-residential buildings with more than six parking spaces and every parking space in new residential buildings with more than five parking spaces must be equipped with conduits for electric cables. This measure is intended to guarantee that new buildings can be equipped or retrofitted with sufficient charging stations for electric vehicles.
After 1 January 2025, every non-residential building with more than twenty parking spaces is also to be equipped with at least one charging point.
In addition, the possibility is to be created to fulfil the charging point obligations for non-residential buildings bundled at one or more locations. Exceptions are envisaged for non-residential buildings that are owned and predominantly used by small and medium-sized enterprises. The same applies to existing buildings if the cost of charging and wiring infrastructure exceeds 7 percent of the total cost of a major renovation.
The GEIG will enter into force one day after its publication in the Federal Law Gazette.
WEEE labelling of electric charging stations
Registered electrical appliances must be labelled in accordance to national legislation. The labelling obligation in Germany is strictly regulated. It is mandatory to indicate the specific name of the appliance manufacturer on the charging station, as well as the respective brand to identify the manufacturer. All information provided on the device must correspond to the information provided by the „Stiftung EAR“.
For charging stations and wallboxes intended for private use, the symbol for prohibited disposal in household waste must be applied. The symbol of the crossed-out dustbin serves as a marking for this. This is applied directly to the product label and type plate.
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Electric charging stations international
Not only in Germany there is a great sense of optimism. Worldwide, the network of charging stations is growing continuously. This means that national legislators are forced to act and create appropriate regulations for the e-mobility infrastructure.
Development of the e-mobility infrastructure since 2012
Overview of the expansion of the e-charging station infrastructure worldwide and in Germany, Spain, France and the USA.
Worldwide
Spain
USA
Germany
France
Source: https://www.goingelectric.de/stromtankstellen/statistik/
As the e-car market in individual countries is growing faster than the number of available electric car charging stations, more regulation and subsidies are to be expected. The EU is still far from reaching its „Green Deal“ target of one million charging points by 2025, and there is no overall roadmap to help e-mobility achieve a breakthrough.
There is no uniform regulation for dealing with the registration obligation in the course of WEEE.
International trade, international obligations: Outsourcing pays off!
Deutsche Recycling supports you with national and international recycling legislation, with services flexibly tailored to your products and regions with a focus on packaging, batteries and electrical appliances.
Background information on the EU “Green Deal”
In the European Green Deal of December 2019, the EU set itself the target of reducing transport-related greenhouse gas emissions by 90% by 2050 compared to 1990 levels. About a quarter of all greenhouse gas emissions in the EU are from transport, especially road transport (72%). A key part of reducing emissions from road transport is the switch to alternative, lower-carbon fuels.
Source: European Court of Auditors
