Obligation to State Copyright and Recycling Fees on EDI Invoices9. April 2021
On January 1st 2021 a new law came into force, specifically Act No. 542/2020 Coll. on End-of-life products, which redefines all obligations pertaining to the extended liability of manufacturers of electrical or electronic waste in the Czech Republic. Suppliers who send their customers invoices via EDI communication (INVOIC) are thus now required to visibly state the recycling contribution on these types of tax documents, too.
The law (the full text can be found here) imposes a new obligation on manufacturers, distributors and retailers selling new electrical or electronic equipment and/or tires to state the costs related to take-back, processing, use and disposal of e-waste or tires. Take-back and recycling costs must now be stated as a separate invoice line item in a clear and visible manner, separate from the total price of the product, especially on a tax document (or receipt, invoice).
The contribution amount should be stated per 1 piece of the product or 1 kilogram of the products sold. Until the end of 2020, it was up to each entity to decide whether they would state the contribution or not. However, the law was passed in the second half of December, which didn’t give the companies much time to make their decision.
New Act No. 542/2020 Coll. Concerns
The obligation extends to all suppliers who either sell or distribute new electrical or electronic equipment and/or tires, regardless of whether these are marketed separately or as part of, or accessories to, other products. Portable batteries and accumulators are exempt from this obligation; in fact, the visible recycling contribution must not be stated in their case. When selling new electrical and electronic equipment, retailers are still required to inform the consumer about the final price according to the price law, which includes all taxes, duties and fees (which also include the visible recycling contribution).
Violations of the new law are monitored by the Czech Trade Inspection Authority and, in the event of an offense, companies face a fine of up to half a million CZK.
How to Fulfill the New Obligation on EDI Invoices
Suppliers have two options of how to issue tax documents and thus fulfill their legal obligation. In both cases, an agreement with the purchaser is necessary.
The first option is to state the newly required data on EDI invoices (INVOIC) in an unstructured way as part of the name of the goods. However, as this data cannot be processed automatically, GRiT does not recommend this approach.
The other option is to systematically follow the methodological guidance created by GS1, which most EDI providers also align themselves with. In this case, the listing of the contribution as a new RTE segment has been newly added to the official specification of the INVOIC message (Subset EANCOM 2002, Syntax 3, Edition 2008).
This change makes different demands on different suppliers. It depends on how they use EDI.
It is the easiest for suppliers who use the webEDI ORiON web application for processing their documents. For all suppliers of Alza and Datart, these compulsory fields of the invoice creation form are now pre-filled and they can start using them immediately.
Suppliers who do not have the above-mentioned customers, but are required to state the recycling contribution on their invoices, may also request to display the new fields. All they need to do is contact ORiON customer support (firstname.lastname@example.org), who will change their display settings.
Companies which have integrated EDI into their ERP systems must now, as a result of the new legislation, modify them. If you do not have your own IT team which takes care of system modifications, please contact your system integrator. For our part, in ORiON we have made all the necessary modifications to transmit the new information on our clients’ invoices. We have also created an overview of these modifications accompanied by examples and recommendations for all of the most commonly used formats, which you can use as a basis for your system modifications. You can download the overview here.