Dual Systems in Germany - Obligations of the initial distributor -

1. Dual Systems in Germany- Obligations of the initial distributor - DeutschlandforumLjubljana

2. Packaging Recovery and Recycling in Germany The Dual System • One of the leading recycling systems worldwide • High demands on industry and trade • 5th amendment  change in the legal situation for visible imports and deliveries from other EU states • 6th and 7th amendment are currently discussed and shall be implemented as of 01.01.2015 • Fulfilling the legal requirements of recycling of sales packaging is very important also for foreign companies

3. Packaging Recovery and Recycling in Germany Licensing of sales packaging • Obligation to participate in a dual system • since 01 January 2009 • all initial distributors foreign companies included • Packaging, which accumulates at the private end users or comparable collection points, are to be participated in a dual system and/or industry solution • Non-licensed packaging = Product is not allowed to be distributed and can lead to fines up to 50.000 €

4. Packaging Recovery and Recycling in Germany Who is obliged? • Companies, which put sales packaging filled with goods into circulation for the first time in Germany = initial distributor • Imported goods: • The company, which at the border crossing bears the legal responsibility for the goods • Foreign companies have same obligations as German companies: • Proper recovery and recycling of packaging via a dual system or an industry solution

5. Packaging Recovery and Recycling in Germany Non-compliance with the licensing obligations • May have very unpleasant consequences: • Sales embargo of the goods put into circulation • High fines (up to 50.000 €) • Legal competition warnings

6. Packaging Recovery and Recycling in Germany Implementation • German business partners are offering for the importers to license the goods by order of a third party • responsibility stays at the importer • is considered in pricing • often related with higher costs than own licensing • Price comparison pays off

7. Recoveredsubstancecycle in the dual system Life cycleofsalespackaging

8. Dual Systems in Germany Dual System Redual • Dual System Vfw

9. Company Portrait Who we are At the locations Herborn, Cologne, Vienna, Toronto and Berlin work today over 200 employees and achieve with 3.000 customers a turnover of more than 200 million euros. Customer satisfaction is our top priority: 2010 we were once again distinguished with the IPS Award by a major customer of the food sector. Environmental quality management and legal certainty are self-evident to us: we are certified according to DIN EN ISO 9001:2008 and DIN EN ISO 14001:2004

10. Company Portrait History Reclay GmbH Foundingby R. Fruscio & M. Schürmann LIZ AG since 2012 Reclay GmbH Majority shareholding Waste & EnergyAG Reclay UFH GmbH WEM GmbH since2014 Reclay Materials GmbH Merger of Tanzer Consulting into Reclay Österreich GmbH 2004 2002 2006 2008 2009 2012 2014 2013 2005 2010 Curanus GmbH Redual GmbH & Co. KGsince2012 Reclay VfwGmbH RE|CARBON GmbH Reclay Österreich GmbH RE|PLA Cycle GmbH Majority shareholding StewardEdge sincethe end of2012 Reclay StewardEdge Takeover VfwGmbH Merger ofVfw GmbH andRedual GmbH to Reclay Vfw GmbH

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12. Development of Turnover Continuous growth characterises us Figures in millions of EUR

13. Development of Staff Numbers Facing the future together * Status: November 2013

14. Market Situation Market shares of the Dual Systems 2nd Quarter 2014 *Dual System Redualand Dual System Vfw

15. Fullserviceprovider One-stop environmental and waste management Customer Report of industry solution “Curanus” Report of dual system “Redual” Green Dot processing Outsourcing of customers’ waste management obligations to Reclay Settlement with other system providers Commissioning of auditors Preparing of declaration of completeness Organising correspondence with third parties Reclay

16. Licensing options Disposalofsalespackagingbycollectionpoints Private end consumer Dual system § 6.1 VerpackV Customer Same status as private end consumer* Industry solution § 6.2 VerpackV Large-scaleindustry Industrial disposal § 7 VerpackV * § 3.11 VerpackV: includes doctors’ surgeries, bakeries, copy shops, printers, airports, restaurants, hotels, snack bars, canteens, agricultural enterprises, museums, opticians, nursing homes, lawyers, sports stadiums, service stations, universities, administrations, Christmas markets, zoological gardens

17. Reclay Austria Reliable packaging licensing as well in Austria • Founded in Vienna in 2009 • Start of a commercial system in form of Reclay UFH in 2010 • Handling of the Austrian market and neighbouring CEE countries • The monopoly of ARA will end as of 01.01.2015 • Licensing via Reclay Austria already in 2014 possible • Consulting in the field of packaging licensing with full legal compliance: • Analysis of sales channels • Optimisation of licensing • Implementation of measures

18. Contact Reclay GmbH Im Zollhafen 2-4 D-50678 Cologne Mario Simon Nea Masur Team Leader SalesSalesAssistant Europe Tel. +49 (0)221 58 00 98 2542 +49 (0)221 58 00 98 2569 Fax +49 (0)221 58 00 98 777 +49 (0)221 58 00 98 777 Mobile +49 (0)175 576 50 21 e-mailm.simon@reclay-group.comn.masur@reclay-group.com