Update as of December 12, 2006
1. Does Slovakia have national legislation regarding Waste Electrical and Electronic Equipment Directive (WEEE) and Restriction of the Use of Certain Hazardous Substances Directive (RoHS)?
On December 2, 2004 Slovakia passed law 733/2004 regarding waste, which became effective January 1, 2005. On April 29, 2005 with the aim of implementing EU legislation regarding WEEE and RoHS into national law, Slovakia published notice 208/2005 and notice 209/2005 entitled "Disposal of Electrical and Electronic Equipment.” These Notices have been in effect since June 1, 2005. Slovakia passed Governmental Decree 388/2005 on Limits, Assessing, Reusing and Recycling of WEEE, which became effective August 13, 2005.
The WEEE law in English is available at the following link: http://www.enviro.gov.sk/servlets/page/317?cid=404&cid=372&cid=179&cid=180&cid=371&type_id=1&cat_id=2786
A Slovak version of the law and notices are available on the following web page: http://www.zbierka.sk
2. Who is a producer according to the Slovak law? Who has to register with the Slovak registration authority?
Slovak legislation fully adopted WEEE directive definitions of a producer, as follows:
- Manufacturers who sell their products under their own brand name
- Resellers who sell equipment under their own brand which are however, actually produced by another supplier
- Importers of WEEE on a professional basis to Slovakia.
All producers must register with the Slovak registration authority. An American firm without a subsidiary in Slovakia is not considered to be a producer and cannot register with the Slovak registration authority. Instead, the company's distributor/agent/reseller must register as the producer. According to law, American subsidiaries in Slovakia are considered to be producers and must register and fulfill all of the responsibilities of a producer.
3. Who is the registration authority in Slovakia?
The Ministry of Environment is the only registration authority in Slovakia. All producers must register with the Ministry. The registration requirement began on June 30, 2005. Contact information for the Ministry of Environment follows:
Ministerstvo zivotneho prostredia SR
Nam. L. Stura 1
Bratislava, Bratislavsky 812 35
Phone: +421 2 59561111, 59562383, 59562388
Information on the web page http://www.lifeenv.gov.sk is available in both Slovak and English. The registration process, however, must be completed in Slovak.
4. Which products are covered by the Slovak law?
All WEEE products are covered:
· Large household appliances
· Small household appliances
· IT and Telecom equipment
· Consumer equipment
· Lighting equipment
· Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
· Toys, leisure and sports equipment
· Medical equipment
· Monitoring and control instruments
· Automatic dispensers
5. What are the deadlines in Slovakia for registering and being compliant with the law?
In Slovakia, registration started in January 2005. Registrations for exisiting companies had to be completed by June 30, 2005. Companies not registered will be banned from selling their products in Slovakia. Products brought to the Slovak market after July 1, 2006 must be RoHS compliant.
6. When will the take back and treatment responsibilities start?
Beginning August 13, 2006, companies must begin to take back and treat WEEE, as well as begin labeling their products and advising the estimated amount of product that they will put into the market.
7. How about B2B products? What are the responsibilities of the producers of B2B products?
Producers are responsible for waste from B2B products brought to market before August 13, 2005 (historical B2B waste). However, producers do not have to finance the treatment of this waste, which is the responsibility of the end user.
For B2B waste from products brought to market after August 13, 2005, producers are free to conclude agreements with the end user regarding the financial responsibility for take back and treatment of the waste.
The Slovak Ministry of Environment interprets the language of local legislation to mean that B2B products must be labeled. Also, EU Commission guidelines recommend that B2B products be labeled.
8. Are there any joint or individual schemes, which companies can participate in?
With the aim of utilizing economies of scale, some large firms have created partnerships and subcontracted their take back and treatment obligations to a single recycling firm. Below is a list of these collective programs:
ENVIDOM: category 1 and 2, e-mail: firstname.lastname@example.org
SEWA: category 3 and 4, e-mail: email@example.com
EKOLAMP: category 5, e-mail: firstname.lastname@example.org
ENVI-GEOS NITRA, s.r.o., Nitra, all categories, e-mail: email@example.com
LOGOS – Slovakia, s.r.o., Bratislava, all categories, e-mail: firstname.lastname@example.org
ENZO – Veronika - VEZ, a.s., Dežerice, all categories excepted category 8, e-mail: email@example.com
BRANTNER Slovakia, s.r.o., Bratislava, all categories, e-mail: firstname.lastname@example.org
ETALUX, category 5, e-mail: email@example.com
ELEKTRORECYCLING, s.r.o., Banská Bystrica, all categories, e-mail: firstname.lastname@example.org
ZEO, s.r.o., Košice, category 6, e-mail: email@example.com
9. How does the take back system work in Slovakia? Who is responsible for what?
Consumers deposit their WEEE free of charge at their municipal collection point. The municipalities are responsible for sorting the waste. When sufficient waste has been collected in WEEE bins (these are provided by the producers), the municipality informs the registration authority. The Authority then determines which of the registered companies is due (on a roster basis) to pick up the waste and requests the company's recycling subcontractor to return the waste. The subcontractor is then responsible for picking up and treating the WEEE. Producers finance this operation. EEE Distributors or sellers can offer their customers a service that collects old WEEE on a free exchange basis when a new EEE piece purchased.
10. What does "put on the market" mean?
Put on the market is the initial action of making a product available for the first time on the Slovak market, with a view to distribute or use in the Slovak market. Making the product available can be either for payment or free of charge.
11. Who can register with the Slovak competent authority?
Slovak producers and resellers of EEE
Foreign producers of EEE with a local entity
Foreign producers of EEE without local entity registered with one of ten collective schemes
Importers of EEE into the Slovak Republic.
12. Which organizations can provide expert information and guidance on the new legislation?
U.S. Commercial Service Bratislava can provide a detailed report on the application of the Slovak law for WEEE and RoHS.
For more information, please contact:
Marian Volent, Senior Commercial Specialist
tel: +421 2 5920 5318
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