The supervising authorities allow for importers and manufacturers to become compliant by becoming a member of Recupel retroactively.
Importers and manufacturers who conclude an entry agreement with Recupel for a specific product group after the start of activities of a specific Managing Body will also have to pay Recupel contributions to Recupel for the goods that are subject to the take-back obligation and that they have marketed since that time.
Only after submission of an approved individual waste management plan can the relevant importer/manufacturer be granted an exception to the aforementioned role for the past. More information
Recupel contributions due retroactively are calculated on the basis of the appliance lists that applied at the time when the relevant EEE was placed on the market. For Recupel contributions due retroactively, default interest calculated at the legal interest rate shall apply.
In order not to discourage importers and manufacturers from becoming a member of a Managing Body, since the cost of the retroactive Recupel contribution would become huge, a seven calendar year prescription applies to the membership agreement, from the year following the calendar year to which the annual collection status refers.
This rule prevents discrimination against members who complied with the legal acceptance obligation in a timely manner.
Retroactivity applies to those importers and producers who were already involved in the import or production of WEEE at the time the obligation became mandatory for the sector in which they are active and for the appliances marketed by them.
For companies whose activities started later, retroactivity obviously only goes back to the beginning of their activity.