On January 1, 2021, the new Act No. 542/2020 Coll. on End-of-Life Products entered into force, which redefines all obligations related to extended producer responsibility regarding electronic waste in the Czech Republic. For suppliers who send invoices to their customers using EDI communication (INVOIC), this created a new obligation to indicate a visible recycling contribution on these tax documents as well.
The law (the full text can be found here ) imposes a new obligation on manufacturers, distributors and final sellers to indicate the costs of taking back, processing, using and disposing of waste electrical and electronic equipment or tyres when selling new electrical and electronic equipment or tyres . The costs of collection and recycling must now be stated as a separate item in a clear and visible manner, separate from the final price of the product , especially on the tax document (or receipt, invoice).
The amount of the contribution is stated in relation to 1 piece of product or 1 kilogram of products sold. Until the end of 2020, it was up to individual entities to decide whether to state the contribution or not. However, the law was approved in the second half of December, and the authorities did not give companies much time to decide.
Who does the new Act No. 542/2020 Coll. apply to?
The obligation applies to suppliers who sell or distribute new electrical equipment and tires. Regardless of whether they are placed on the market separately or as a part or accessory of other products. Portable batteries and accumulators are exempt from this obligation, for which a visible recycling contribution may not be indicated . When selling new electrical equipment, the obligation of the last sellers to inform consumers of the final price according to the Price Act, which includes all taxes, duties and fees (which also include a visible recycling contribution), still applies.
Violations of the new law are monitored by the Czech Trade Inspection Authority, and companies facing a fine of up to half a million CZK for violations.
How to fulfill the new obligation on EDI invoices
The supplier essentially has two options for issuing documents and thus fulfilling the legal obligation. However, both must be agreed with the customer. The supplier should therefore clarify with the customer whether the solution is acceptable.
The first option is to provide the newly required data in EDI invoices (INVOIC) in an unstructured manner as part of the product name. Due to the impossibility of processing this data automatically, GRiT does not recommend this solution .
The second option is to systematically follow the methodology developed by GS1, which is generally agreed upon by EDI providers. In this case, the official specification of the INVOIC message (in the EANCOM 2002 subset, Syntax 3, Edition 2008) has newly added the inclusion of the contribution as a new RTE segment.
This change has different demands on suppliers, depending on how they use EDI.
It is easiest for suppliers who use the webEDI ORiON web application to work with documents. All suppliers of Alza and Datart have these mandatory fields added to the invoice creation form and can start using them immediately.
Suppliers who do not have the above-mentioned customers but must include the recycling contribution on invoices can also request the display of the new fields. Simply contact ORiON support ( podpora.orion@grit.cz ), who will set up their display.
Companies that have EDI integrated into their ERP systems must modify them due to the new legislation. If you do not have your own IT team that takes care of system modifications, contact your system integrator. At ORiON, we have already made all the necessary modifications to transfer the new information on client invoices. We have also prepared an overview of these modifications with examples and recommendations for all the most commonly used formats, according to which you can proceed with the modifications of your systems. You can download it here .
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