1. Evolving Framework: Recent Changes to EPR Legislation in Croatia

Croatia recently implemented significant updates to its EPR regulations for packaging, WEEE (Waste Electrical and Electronic Equipment), batteries, and other products. These changes, effective November 2023, aim to align Croatia with EU standards and promote sustainable waste management.

Key Changes:

• Packaging Regulations:
  • Fully implements EU Packaging and Single-Use Plastics Directives.
  • Defines new producer responsibilities, including web platforms.
  • Requires foreign companies to appoint authorized representatives.
  • Introduces a mandatory deposit system for single-use beverage packaging.
  • Establishes new rules for deposit labels.
  • Mandates financing for anti-littering measures, prohibits lightweight plastic bags, and promotes beverage cup consumption reduction.
• Regulation on Special Waste Management:
  • Maintains most existing EPR requirements for WEEE and batteries.
  • Requires producers of automotive and industrial batteries to cover full end-of-life financing.
  • Imposes EPR obligations on web platforms.

2. Understanding EPR Policy: Shifting Responsibility and Design Incentives

The OECD defines EPR policies as those that:

• Shift Responsibility Upstream: Producers, not municipalities, take on the financial and logistical burden of waste management for their products.
• Incentivize Sustainable Design: Producers are encouraged to consider environmental impacts throughout the product lifecycle, promoting eco-design and resource efficiency.

3. Targeted Products: Prioritizing Waste Streams

While EPR can apply to any product, Croatia focuses on three core categories:

• WEEE (Waste Electrical and Electronic Equipment): High volume and often contain toxic components.
• Packaging: Significantly contributes to waste streams.
• Batteries: Contain hazardous materials and require specialized handling.

These categories pose environmental risks when improperly disposed of.

4. Who Needs to Comply? Identifying EPR Producers

Any business that manufactures, imports, sells, or brand-owns products or packaging covered by EPR regulations can be considered a producer. Companies meeting any of these criteria must review EPR legislation in every country they operate in to ensure compliance. Additionally, some countries may have thresholds, such as minimum turnover or product quantities, that determine if a business is subject to EPR obligations.

5. Navigating Compliance with Interzero

Interzero, a global waste management and recycling leader, offers expertise in EPR compliance across Europe. With over 30 years of experience and an international team, we can help your business understand its EPR obligations in Croatia.

Additionally, Interzero provides:

• An online portal to easily manage your EPR compliance in Croatia (https://epr.interzero.hr).
• Assistance in simplifying and digitizing the compliance process.

By partnering with Interzero, businesses can ensure compliance and contribute to a more sustainable future.

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What does this mean for foreign producers and webshops that deliver to Croatia?

Foreign producers as well as webshops (online internet platforms) that have their business headquarters in another country are obliged to authorize in writing a registered person in Croatia who, as an authorized representative, is responsible for fulfilling their obligations.

In doing so, it is important to emphasize that foreign producers have obligations in Croatia only and exclusively if they place packaged products on the Croatian market by direct sale to a natural person – a citizen through a distance contract (online).

If a foreign producer sells directly to B2B end users or distributors, there is no obligation to fulfill EPR obligations. A Croatian company that buys products for its own use or resale has these obligations.

Why is that so?

Placing on the market is considered the first registration or first entry into the business records of a product by a company/trade registered in Croatia. As according to Croatian regulations, every purchase and sale between legal entities represents a business event that must be subject to accounting records, therefore every invoice must be entered in the business books, this means that the company/trade registered in Croatia, which first in Croatia, is liable for the payment of the management fee records the product and therefore puts the product on the market in the territory of Croatia.

As natural persons – citizens do not have this obligation of accounting records and the mentioned products as well as the associated packaging are not registered in the business books – the foreign producer is obliged to fulfill the EPR obligations for that part of the packaging, which, as we have already stated, fulfills its obligation through an authorized representative.

What about products sold through online platforms to citizens?

A network internet platform that provides a distance sales service to producers who have not registered in the Register/Fund as described above, is considered a producer for all quantities of products placed on the market by such a producer and is responsible for fulfilling the obligations of that producer. If the online platform is based outside Croatia, it is also obliged to appoint an authorized representative in Croatia.

Let’s go back to the ways and terms of data delivery

The legally prescribed deadlines for the delivery of packaging information is once a month by the 20th day of the month for the previous month.

Until the Registry is established (and currently is not established) these deadlines do not apply and data are sent quarterly by the 10th of the current month for the previous quarter.

Foreign producers send the data to the authorized representative as agreed, but before the deadline for submitting the data to the Fund, so that the authorized representative has enough time to prepare a report and fulfill obligations before the Fund on behalf of the foreign producer.

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Ordinance on the management of special categories of waste in the Fund system (OG 124/23)

It contains procedures and conditions for managing waste EE equipment, waste vehicles, waste batteries and accumulators, waste tires and waste oils, under one place.

It is important to define that the producer means producer of products that are placed on the market in the Republic of Croatia, regardless of the sales method, using remote communication, that sells EE equipment, B&A (portable B&A as stand-alone products) directly to households or non-household users in the Republic of Croatia, and has its business headquarters in another EU member state or a third country. But the obligation to authorize an authorized representative in the Republic of Croatia have only those that sell directly to a natural person, to a citizen (household or B2C). Others can fulfil their obligations by themselves, but they can also be supported in actions when help is needed.

The news is that it is defined also that a network (internet) platform that doesn’t have its business headquarters on the territory of the Republic of Croatia, is considered a producer and, relying on the above, must authorize an authorized representative in the Republic of Croatia.

Producer with business seat outside Croatia = an AR in Croatia

Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic (OG 137/23)

Provisions apply to all packaging placed on the market and to all waste packaging, regardless of the material used.

The principle is the same… Producer of packaged products that has business headquarters in another EU member state or a third country and sells directly to a natural person, to a citizen (household or B2C) is obliged to authorize, in writing, an authorized representative in the Republic of Croatia. Also applies to a network (internet) platform that doesn’t have its business headquarters on the territory of the Republic of Croatia.

Producer with business seat outside Croatia = an AR in Croatia

Producers have an obligation to register and submit data to the Register of producers with extended responsibility. Management fee is calculated based on that data and paid monthly for the amount of products that the producer put on the market in the territory of the Republic of Croatia in the previous month. In order to implement the obligation, the producer (its authorized representative) is obliged to calculate and pay the management fee to the account of the Fund.

The obligations of the AR are unchanged and they include fulfilling the EPR obligations of the producer or the platform in accordance with the Ordinance, communication with the Fund, management fee, monitoring the Register of producers with extended responsibility.

Until now, registration and reporting of data for packaging and batteries and accumulators took place quarterly, and the new thing is that it will be reported monthly, as was the case with EE equipment so far.

Photo: xdfolio on pixabay

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In 2021, more than 58 million tons of food, including edible and inedible parts, were thrown away in the European Union, which is about 131 kg per capita! For cosmetic reasons, 50 million tons of fresh fruit and vegetables are thrown away annually in Europe.

More than 286,000 tons of food waste, 71 kg per inhabitant, are thrown away in Croatia every year! The value is around 600 million dollars, and the goal is to reduce the figure by 30 percent by 2028.

Of the total number of discarded food in Croatia, 76% comes from households, and 24% from the business sector. Most often, household food is thrown into mixed municipal waste, then disposed of in a composter and thrown into biowaste. Also, households often buy big amounts food, and therefore it is thrown away more often. The most worrying thing is that a very large part of the food thrown away is still edible food. It is thrown away due to the excessive amount of purchased and/or prepared food and due to the expiration date. For this reason, interesting and instructive conferences, activities and projects are organized.

The most expensive foods are thrown away, primarily meat, then fruits, vegetables, and potatoes

It is commendable that the food donation system in Croatia is getting better, and it is planned that the Food Banks will take over the role of coordinators in donating and start working at the beginning of 2024 at the latest. The legislative framework for donating food was also improved and an IT system was established, which has already saved 700 tons of food. Positive examples from Europe and the world are being used more and more, and through business processes, efforts are being made to throw away as little food as possible in production and use all leftovers, in order to complete the whole story with an emphasis on zero waste.

The packaging also creates a problem

Food waste is responsible for an average of two tons of carbon dioxide equivalent per person each year

Researchers from the EU are developing ways to reduce food waste, as well as its packaging. The problem of waste goes beyond the food itself and includes its packaging, for which the industry produces a lot of plastic. Very little food packaging is compostable, and many plastic forms cannot be recycled. It is necessary to work on more durable bio-based materials that would be strong enough to support food and that could be decomposed after use. On the other hand, packaging should be designed using materials that can be fully composted or recycled.

In the EU, legislation requires that most prepackaged foods contain a date that indicates the threshold of their safety (“use by”) or quality (“best before”). As part of a general review of food labeling rules, the European Commission is considering a proposal to completely abolish the use of “best before” dates.

Climate change could make imperfect food the norm in shopping, not a choice

Solving the problem of consumer food waste remains a challenge both in the EU and worldwide. Education is also important for achieving goals, especially when it comes to excessive food waste in households. With sustainable habits that each of us can adopt very easily, we will make our environment more beautiful and greener, without waste. For everyone involved in the food supply chain, it is important to have a good and sustainable waste management plan, from start to finish. Contact the experts who will work with you on sustainability, consulting, who will produce sustainable and recyclable packaging with you, and who will offer you solutions for your waste.

Source: https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Food_waste_and_food_waste_prevention_-_estimates

https://www.euronews.com/green/2022/09/29/convincing-people-to-buy-wonky-vegetables-could-help-reduce-food-waste

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The number of mobile phones will exceed the number of human beings in the next few years, it is a staggering 18 billion by 2025

Of the approximately 1.5 billion phones sold each year, only 20% are recycled

Do-it-yourself repairs to extend the life of your device

The modular design increases the perception of self-repairability, while well-designed instructions lead to a positive repair experience

Most producers focus on recycling discarded devices instead of extending their life. However, certain smartphone producers have embraced the principle of repairable, modular design and materials that are more easily recycled. A modular design where parts of the product can be replaced and upgraded promises to extend the life of a particular product. Such a design promotes do-it-yourself repairs, and in order to realize the potential, it is very important that users are willing to repair their devices.

A user-centric approach is key to developing products and business models that promote repair. Producers thus need to address the different types of obsolescence that users encounter (not only technical failure but also all other factors that may lead users to reject the product).

Users of modular devices are more likely to repair the device themselves, while more complex elements such as motherboards are still more often sent to service

Consumer behavior research for a German smartphone producer that offers semi-modular and modular devices along with affordable and easy repair and DIY repair service found that consumers are more likely to engage in sustainable behaviour. That is, that they will carry out repairs on defective parts. It’s going in the right direction, earlier research showed that half of the users of conventional smartphones would rather discard defective devices than send them in for repair.

Self-repair can also increase emotional attachment to the product, which delays product replacement

Sustainable innovation

About 75% of CO₂ emissions from phones are released during the production phase

Considering that it is not uncommon to need to buy a new phone on average every couple of years, there has been a need to stop ignoring the damage that is done and the desire for smartphones that last a long time, do not represent an expense and do not exploit mines.

Fairphone, launched by a Dutch social enterprise in 2012, fights e-waste, pollution and exploitation of the environment and materials. They avoided enviable amounts of CO₂. Its parts are available and can be repaired with a screwdriver, with video tutorials on the Internet. The sustainability of this device is achieved by its modularity, which makes it easy to repair, and they also offer the return of old parts, which they plan to expand to more countries. With this solution, they aim to correct everything that is wrong in the supply chain and inspire the smartphone industry to be better.

The European Union is working to introduce a “right to repair” for certain devices to reduce e-waste

Another good example is Austria, which helped pay for more than half a million repairs in an effort to solve the e-waste problem. The government’s repair program covers faulty appliances such as smartphones, laptops, coffee makers and dishwashers. They have provided consumers with a large number of locations across the country where they can bring their faulty devices and redeem the vouchers.

According to the European Commission, discarded technology produces 35 million tons of waste and 261 million tons of CO₂ emissions every year in Europe

The program plans to reduce waste by giving consumers the right to repair instead of replacement and making repairs easier and more cost-effective. In addition, it would avoid “planned obsolescence”, which makes the product unusable after a certain period, without the possibility of repair. These ventures will encourage producers to develop sustainable products and business models. The “right to repair” in the EU would work so that producers, within the legal warranty period for the product, would be obliged to offer repair services if it does not cost more than replacement. Even after 5 to 10 years after the date of purchase, producers would be required to repair the products, but at the expense of the consumer. Also, producers should disclose product repair information.

Ease of repair, repair incentives and ways to upgrade phones should be the focus. Phone producers and retailers should actively promote consumer awareness of repair options. Incentive strategies such as repairability ratings could be useful in influencing more sustainable product choices. Also, what is often easier said than done, for a more sustainable awareness it would not be bad to resist the aesthetics and seduction of the marketing of certain products, although in essence the technical difference of the products themselves is not that great. Finally, an EU price-level “right to repair” law could soon make it easier to repair rather than replace and discard electronic equipment and devices.

Source: https://environment.ec.europa.eu/news/sustainable-smartphones-modular-design-promotes-do-it-yourself-repair-extend-device-life-2023-02-15_en#:~:text=Sustainable%20smartphones%3F-,Modular%20design%20promotes%20do-it-yourself%20repair%20to%20extend%20device,willing%20to%20repair%20their%20devices https://www.euronews.com/green/2023/06/05/sick-of-buying-a-new-phone-every-two-years-fairphones-last-for-years-and-dont-exploit-mine https://www.euronews.com/green/2023/05/02/austria-has-helped-pay-for-more-than-half-a-million-repairs-in-bid-to-tackle-e-waste

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A big problem for the environment – vape waste

Tobacco waste is one of the biggest sources of plastic pollution. A trillion cigarettes are thrown away every year, littering the soil and sea with toxic chemicals and harmful plastic. Today, this new stream of e-waste, e-cigarettes, joins this. Although this new way of smoking is presented as a better alternative to classic tobacco smoking, it is increasingly clear that there is reason to be concerned about the impact on health and the environment. Both in Europe and in the rest of the world.

Almost three quarters of people in the UK do not recycle their used vapes.

According to research by the e-waste recycling organisation, more than 1.3 million disposable vapes are thrown away every week in Britain, which would mean two e-cigarettes are thrown away every second. Imagine how many will be discarded while reading this article!

It is for this reason that the UK Government will propose plans to tackle the disposal problem as part of a wider reform of e-waste regulations. While there are proposals to ban single-use vape devices, it is more likely to go in the direction of forcing producers to better design their products and pay to recycle them. Producers currently do not provide clear instructions on how to dispose of their products and, in addition, counter-productively advertise and encourage the single-use of products, instead of emphasizing recycling and reuse.

Under UK law, shops are required to collect and recycle all small electronic items free of charge, regardless of whether the vape was purchased there or not. Smaller stores that cannot do this should pay a fee to finance the collection and processing of these products when they become waste. At least that’s how it is in theory.

Demanding recycling

E-cigarettes come in many shapes and sizes. Some are reusable and filled with disposable plastic cartridges, and some are completely disposable. Be that as it may, there is a lot of waste. They are rarely recycled, and 30% are reused. Even when recycled, the components are a fire hazard even if properly disposed of.

Disposable e-cigarettes, which consist of a lithium battery attached to a cartridge and lined with colored plastic, are difficult to handle properly. When breaking down their batteries and circuit boards, vape devices release toxic chemicals into the environment, and the casing grinds into harmful microplastics.

In addition to taking up space in landfills and harming the environment, not recycling lithium and other valuable parts such as copper also represents a loss in the demand for metals, which is crucial in today’s rapidly electrifying world.

A vape device contains an average of 0.15 g of lithium.

On the aforementioned 1.3 million devices discarded each week, this would mean 10 tons of lithium per year, equivalent to the lithium in the batteries inside 1,200 electric vehicles.

Unfortunately, most people are not aware and do not think about what happens to their e-cigarette when they throw it away. The rest, who may be thinking in the right direction, often remain limited in their options and end up throwing them in the trash.

As with the rest of the waste, especially e-waste, local recycling centers run by municipalities, large supermarkets and electrical stores should all be helpful. Recycling needs to be enabled and facilitated, producers and retailers need to work together to become part of the solution. Also, each country is an indispensable factor in promoting safe recycling and waste reduction.

Fortunately, where there is an environmental problem, there are also many ideas that go towards solving each such problem in a sustainable way.

Source: https://www.euronews.com/green/2023/08/01/planet-of-the-vapes-how-big-a-problem-are-e-cigarettes-and-where-can-they-be-recycled

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Consumers will soon be able to use one charger for all their portable electronic devices in the EU. USB Type-C will become a common charging port by autumn 2024, Parliament and Council negotiators agreed in June 2022. The law establishing a single solution for charging certain electronic devices is part of the EU’s wider efforts to make products in the EU more sustainable, to reduce electronic waste and to make life easier for consumers. You can watch the press conference here.

According to the new rules, consumers will no longer need different charging devices and cables if they buy a new product and will be able to use one charger for their electronic devices. Regardless of producer, all mobile phones, tablets, e-readers, earbuds, digital cameras, handheld video game consoles, and portable speakers that charge via a wired cable will need to have a USB Type-C port. The charging speed is also harmonized, allowing consumers to charge their devices at the same speed with any compatible charger. Laptops will also have to conform to the requirements for up to 40 months after the entry into force.

• One charger for frequently used small and medium portable electronic devices
• Charging speed adjusted for devices that support fast charging
• Consumers can choose whether they want to buy a new device with or without a charger

Clear information about the charging characteristics of new devices will be made available to consumers, making it easier to check the compatibility of their existing chargers.

The new obligations will lead to greater reuse and consumer savings of 250 million euros per year on purchases of unnecessary chargers. In addition, it is estimated that discarded and unused chargers represent 11,000 tons of e-waste per year!

https://oro.hr/wp-content/uploads/2023/09/A-common-charger-for-electronic-devices-June-2022-2.pdf

Almost half of the waste electrical and electronic equipment (WEEE) in Europe is not properly collected and recycled

The WEEE Directive requires member states to collect 85% of all WEEE produced. Public data on WEEE is not always available, but there is good data on officially collected and recycled WEEE which is documented by Member States when they report on their progress towards the WEEE Directive targets. WEEE collection and recycling targets based only on reported e-waste streams ignore the huge recovery potential of valuable materials such as cobalt, gold and copper, in undeclared streams. For this reason, policy makers, compliance and recycling programs need reliable figures to effectively manage this waste.

However, little is known about the flow of undeclared WEEE through society, whether it is recycled, disposed of or exported. Much WEEE flies under the radar as consumers often dispose of it in household waste or it is mixed into mixed metal waste streams where it is recycled, but not under WEEE compliant conditions. In addition, large amounts of WEEE are disposed of by being scrapped for parts before being officially collected or exported abroad, both legally and illegally.

EU research results suggest that 30 countries (all current member states, Norway, Switzerland and the UK) discarded approximately 9.7 million tonnes of WEEE, both declared and undeclared, in 2018. Slightly more than half, 5 Mt, was reported by member states.

Of the undeclared WEEE, it was estimated that 12% (1.12 Mt) was recycled under non-compliant conditions as part of mixed metal waste. A further 7% (0.64 Mt) was extracted for valuable components, 6% (0.6 Mt) was disposed of as household waste, and 3% (0.29 Mt) was legally exported. The remaining 21% (2.09 Mt) is missing and could be illegally exported.

Why are changes important? The amount of WEEE in Europe is growing and will continue to grow

In 2019, 12 Mt of WEEE was produced in the EU, which corresponds to 16.2 kg per person. Consumers should be given more incentives to recycle their old products. In addition to monetary benefits, they should be offered information about product sustainability to encourage product reuse and repair. This will achieve sustainable thinking, changes in purchasing and the adoption of the principles and practices of the circular economy. It is very effective to design products that are easier to recycle.

As wireless charging technology becomes more and more prevalent, the European Commission will be authorized to develop delegated acts on the interoperability of charging solutions. In addition, legal frameworks need to be strengthened to prevent illegal exports and investments in recycling technologies are needed. Accordingly, the emphasis is on designing and evaluating effective WEEE management measures.

Source: https://www.europarl.europa.eu/news/en/press-room/20220603IPR32196/deal-on-common-charger-reducing-hassle-for-consumers-and-curbing-e-waste ; https://environment.ec.europa.eu/news/improved-weee-data-give-better-picture-collection-and-recycling-rates-2022-12-07_en

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Waste Electrical and Electronic Equipment (WEEE) legislation was first adopted in 2002 to prevent or reduce adverse impacts on the environment and human health in the EU. The Commission has since evaluated and revised the Directive in 2012.

The first legislation on WEEE, Directive 2002/96/EC, was adopted in 2002, and ten years later the revised and reformed WEEE Directive was adopted, with the aim of providing a regulatory framework for collection and recycling that would include ambitious targets and encourage Member States to increase preparedness for reuse, to strengthen the incentive for resource efficiency in Europe.

The 2012 Directive also provided member states with tools to identify illegal waste exports more effectively. In addition, it provided for the harmonization of national registration and reporting requirements. The registers of producers of electrical and electronic equipment in the member states are more integrated, and an implementing regulation establishing a harmonized format has been adopted. And additional implementing regulations on joint actions were adopted to ensure uniform conditions.

WEEE is one of the fastest growing waste streams in the EU and globally. If not treated appropriately, it is dangerous and can have serious consequences for people and the environment. In addition, it contains precious and critical raw materials, the recovery of which is essential to support the circular economy and strengthen the strategic autonomy of the EU. In the years ahead, growing consumption and digitization will present ever-increasing challenges, so it is necessary to assess whether the WEEE Directive is fit for purpose.

The Commission launched an online public consultation on the evaluation of the Waste Electrical and Electronic Equipment Directive – WEEE Directive. The consultation lasts until September 22, 2023.

More informations: https://environment.ec.europa.eu/topics/waste-and-recycling/waste-electrical-and-electronic-equipment-weee_en

The ongoing evaluation aims to assess how effectively the Directive has been applied and what its effect has been, to assess how it contributes to the general political goals of the European Green Plan and the Circular Economy Action Plan, and to identify gaps in its implementation. Depending on the findings of the evaluation, the Commission could then initiate the revision process of the Directive.

In the context of the evaluation, the Commission will evaluate the reduction of administrative burdens and the level of compliance achieved after the adoption of the implementing acts. In particular, the Commission is seeking feedback on the identification of equipment containing critical raw materials and on existing recycling practices for these materials. The assessment will also take into account international developments, such as the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

The Directive sets stricter collection and recovery/recycling targets. Separate collection of EE waste from unsorted municipal waste is necessary to ensure its proper processing, but remains a major challenge in most member states. As part of the evaluation, the Commission carried out a compliance promotion initiative to assess good practices and gaps in implementation, among the practices being the separate collection and procedures of WEEE.

The Directive will also be evaluated against the objectives set out in the European Green Plan and the Circular Economy Action Plan and will take into account all other relevant changes in EU environmental and waste policy (e.g. renewable energy policies, batteries, eco-design for sustainable products , restriction of hazardous substances in electrical and electronic equipment, waste vehicles, waste shipments, critical raw materials).

The safe and environmentally sound management of WEEE requires the involvement of a wide range of actors: producers of electrical and electronic equipment, producer responsibility organizations and extended producer responsibility programs, recyclers, entities involved in reuse and preparation for reuse, national governments, third country authorities that receive WEEE, non-governmental organizations as well as citizens.

Source: https://environment.ec.europa.eu/news/commission-consults-citizens-and-stakeholders-directive-waste-electrical-and-electronic-equipment-2023-06-16_en

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By managing waste, costs for raw materials are reduced, energy is saved, people live better and healthier, and a better future is ensured. For these reasons, clear goals have been set at the European level so that all member states work together in the same direction and achieve a synergistic effect.

Electrical and electronic waste

EE waste, as well as waste batteries and accumulators and waste packaging, is a special category of waste for which a system of extended responsibility of product producers has been established as a set of measures taken in the Republic of Croatia to ensure that product producers bear financial or financial and organizational responsibility for the “waste” phase in the product life cycle.

Electrical and electronic devices and equipment (EE equipment) represents all products and their components that for their primary and proper operation depend on electricity or electromagnetic fields as the primary source of energy, …

Electrical and electronic waste (EE waste) is EE equipment that is waste in the sense of the law governing waste management in the Republic of Croatia, including all components, sub-assemblies and consumables that form part of the product at the time of disposal.

Am I/my company obliged to pay?

Producers of EE equipment are obliged to pay a fee for EE waste management in order to cover the costs of separate collection and processing of EE waste in the system managed by the Fund for Environmental Protection and Energy Efficiency.

The producer of EE equipment represents a legal or physical person – a craftsman, who puts EE equipment on the market in the Republic of Croatia, that is, a person who, regardless of the method of sale:

• has its business headquarters in the Republic of Croatia and on the territory of the Republic of Croatia resells equipment produced by other suppliers under its own name or trademark, whereby the reseller is not considered a “producer” if the producer’s name or trademark is on the equipment,
• has its business headquarters in the Republic of Croatia and produces EE equipment under its own name or trademark, or had EE equipment designed or produced that it sells under its name or trademark within the Republic of Croatia,
• has its business headquarters in the Republic of Croatia and in the Republic of Croatia on a professional basis puts EE equipment on the market from a third country or from another EU member state or
• using long-distance communication, sells EE equipment directly to households or users who are not households in the Republic of Croatia, and has its business headquarters in another EU member state or a third country.

The payer is obliged to report the mentioned activities, i.e. the amount of products and/or equipment, and receives a Decision for the same, which determines the amount of compensation he is obliged to pay.

A person who has a business seat in another EU member state or a third country, and places EE equipment on the market in the Republic of Croatia, is considered a “producer” in terms of the provisions of the Ordinance and is obliged to authorize in writing a registered person in the Republic of Croatia, who is, as authorized representative responsible for fulfilling the obligations of that producer in accordance with the Ordinance.

A producer with headquarters in the Republic of Croatia and using remote communication to sell EE equipment directly to households or other users in another EU member state where it does not have its business headquarters, is obliged to appoint an authorized representative in writing as a person who is on the territory of that member state EU responsible for fulfilling the obligations of that producer in accordance with Directive 2012/19/EU.

Foreign companies must have an authorized representative in Croatia.

Design, production and labeling of EE equipment

The producer is obliged to ensure that the EE equipment that is placed on the market is designed and produced in such a way that the use of hazardous substances in the EE equipment is reduced to the minimum possible while respecting the restrictions, that it is possible to disassemble and recover EE waste, especially the reuse and recycling of components and materials, that the EE equipment is in accordance with the technical requirements for eco-design of the product, that in the production of the EE equipment, recycled material was used to the greatest extent possible, but also that the EE equipment that becomes EE waste does not pose a danger or damage to human health and the environment, as well as an obstacle in the management of EE waste.

The producer must also ensure that the EE equipment is legibly and in a visible place clearly and indelibly marked with a mark on the separate collection of EE waste, and if this is not possible due to size or function, it must be printed on the packaging, instructions for use and warranty card. Also, the EE equipment must contain a legible and visible inscription about the producer and a mark that the EE equipment was put on the market after August 13, 2005.

What if the products are exported?

The producer/importer who paid a fee to the Fund during import/production has the right to a refund of the fee in case of product export. For all management fees, in order to exercise the right to a refund, it is necessary to submit a completed prescribed form and attach to it the mandatory supporting documentation. It should be noted that for some fees there is a clearly prescribed deadline for submitting the refund request, and it is necessary to take care of it.

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Estimates show that consumers saved over 63 billion euros in 2020 thanks to these policies.

On 16 June 2023, the Commission proposed new rules to help consumers make informed and sustainable decisions when buying mobile phones and tablets, in line with the existing EU Energy Labelling Regulation. On the same day, the European Parliament and the Council approved measures to increase the energy efficiency, durability and easier repair of devices, following the Commission’s proposal in November 2022, in accordance with the EU Ecodesign Regulation.

All the above measures help the EU economy to be more circular, save energy, reduce the carbon footprint, support circular business models and deliver the benefits of the European Green Deal for consumers.

According to the then proposed Energy Labelling Regulation, smartphones and tablets placed on the EU market will have to display information about their energy efficiency, battery life, protection against dust and water, and resistance to accidental drops. The novelty is that the product placed on the EU market will have to have a repairability assessment, which will help consumers in the EU to make more informed and sustainable decisions when purchasing and thus encourage sustainable consumption.

Devices manufactured according to these rules will save almost a third of today’s primary energy every year until 2030.

The use of critical raw materials will be optimized and recycling will be facilitated. The new products will use the existing and known EU energy labels of the A-G scale, and the European database will provide additional product information through the European Product Register for Energy Labels EPREL, https://eprel.ec.europa.eu/screen/home.

The newly approved Ecodesign Regulation sets minimum requirements for mobile and wireless phones and tablets placed on the EU market, and these include:

• Resistance to accidental drops and scratches, protection from dust and water and the use of sufficiently durable batteries, which means that the batteries should withstand at least 800 charge and discharge cycles while retaining at least 80% of their initial capacity
• Rules on disassembly and repair, including obligations of manufacturers to make critical spare parts available to repairers within 5-10 working days and up to 7 years after the end of sales of the product model on the EU market
• Availability of operating system upgrades for longer periods, at least 5 years after the product has been put on the market
• Non-discriminatory access to professional service technicians for any software or firmware required for replacement

After entry into force, both proposals provide for a transition period of 21 months before the requirements become applicable.

What follows is the submission of these rules on energy labelling to the European Parliament and the Council for a two-month review period, after which they will be officially adopted if there are no objections to the text. In order to harmonize the entry into force of these two laws that refer to the same category of products, their publication in the Official Gazette will take place on the same day, after the adoption of the rules on energy labelling.

Source:

https://ec.europa.eu/commission/presscorner/detail/en/ip_23_3315

Photo: Bru-nO on pixabay

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