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Updating the registration in the National Register of EEE/batteries producers

In this issue:

March 20th/February 28th – deadline for updating the registration in the National Register of EEE/batteries producers at NAEP

Annually, until March 20th, producers and importers of electrical and electronic equipment ("EEE") are liable to update the registration in the National Register of EEE producers at NAEP. For batteries and accumulators, the deadline for the annual registration update is February 28th.


What are the main liabilities/responsabilities of producers/importers of EEE and batteries and accumulators?

In addition to registration and annual updating liability, producers and importers of EEE also have other responsabilities, among which the reporting obligations to both NAEP and the Environmental Fund Administration as well as the collection obligation.

This year, the collection rate is 45% and from 2021 it increases to 65% of the average mass of the quantity of EEE placed on the market in the previous 3 years. For batteries/accumulators, the collection rates is 45% from the average mass of the quantities placed on the market in the current year and the previous 2 years.

This collection objective can be achieved individually or by transferring of responsibilities by contracting an collective organization authorized in this respect.

The individual fulfillment of the objectives is conditioned by the presentation of an operating plan that presents all the activities that they will carry out and the way in which they will fulfill the obligations both for the EEE and for the batteries/accumulators. This operating plan is evaluated and approved by ANPM. In addition, in the case of EEEs, each manufacturer must provide a guarantee, demonstrating that the management of all waste from that EEE will be financed.


How does the above influence the activity of your company?

We recommend that you start the registration/updating process of registration at NAEP, given that, in addition to the fine of up to 50,000 lei, you may also face the risk of temporar suspension of your activity until compliance.

We also recommend that you analyze to what extent the company fulfills its liabilities regarding EEE/batteries and accumulators and take the necessary measures to ensure compliance with the legal provisions.

Prepared by:
Daniela Neagoe – Senior Manager, Indirect Tax
Mihai Petre – Director, Indirect Tax
For additional information, please contact:
Alex Milcev – Partner, Tax & Law Leader Romania
Ernst & Young SRL
Bucharest Tower Center Building,
22nd Floor, 15-17 Ion Mihalache Blvd.,
Sector 1, 011171, Bucharest, Romania
Tel: (40-21) 402 4000, Fax: (40-21) 310 7124
Email: office@ro.ey.com
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