Who is a Producer?
The first person to put the tyre on the market (as a tyre sale or on a vehicle) is the Producer. As a Producer you must join Repak ELT and register with the Producer Register limited (PRL) at producerregister.ie
Under the regulations you must charge the vEMC due on each tyre sold and show it as a separate line item where the sale price of the tyre is shown.
What do the regulations mean for you?
- You must join and report to Repak ELT.
- You must register and report to the PRL and may avail of the opportunity to opt in to share your data securely and confidentially with Repak ELT.
- You must charge the vEMC due on each tyre sold, as a separate line item.
- You must display your Repak ELT membership certificate.
- A producer is prohibited from placing tyres on the market if you are not registered with PRL.
- A producer who is established in another Member State or a country outside of the European Union may, by way of exception to Regulation 9, appoint an authorised representative to fulfil the obligations of that producer pursuant to these Regulations.
8 simple steps for joining Repak ELT
1. Complete your membership application for Repak ELT.
2. Email firstname.lastname@example.org to request your login details.
3. Complete your back reporting and opening stock for retail tyres.
4. Adjust your software/ till system to show the vEMC.
5. Check that your customers have joined the scheme.
6. Display your Repak ELT membership certificate prominently in your business.
7. Register with PRL and display PRL number on all documents.
8. Brief your staff and customers.
Reporting is completed from 1st to 15th of each month.
Visible Environmental Management Cost (vEMC)
As the first person to put the tyre on to the market you must charge the vEMC to you customer. Your reporting will indicate an aggregate of the level of vEMC you have charged to your customers each month and you will be invoiced by Repak ELT for this amount.
The vEMC is paid to you by your customer and they then charge it on to their customer, which carries down throughout the distribution chain concluding at retail level. The vEMC is paid back to the tyre supplier at each step in the chain.
The visible Environmental Cost (vEMC) must be listed separately everywhere the price of the tyres is shown – on your website, invoices, receipts, catalogues etc.
If you delay in joining you are liable for all vEMC on all tyres from October 1st.
There are currently two categories of tyres that have a vEMC. Motorcycle tyres have a vEMC of €1.50 (€1.85 including 23% VAT) and Passenger car tyres have a vEMC of €2.80 (€3.44 including 23% VAT)
Passenger car tyres include those for passenger cars, 4 x 4 vehicles and vans. This category also covers tyres for car trailers and livestock trailers.
Passenger car tyres are categorised in the Regulations as tyres up to the weight of 13kg. The relevant vEMC must be charged on a tyre whether it goes on the vehicle or trailer.
Producers report to Repak ELT and the PRL. You also have the opportunity to share your data securely and confidentially with Repak ELT.
The Waste Management (Tyres and Waste Tyres) Regulations 2017 define a ‘Retailer’ as anyone who “for the purpose of trade or otherwise in the course of business as a wholesaler or supplier, sells or otherwise supplies tyres to other persons”. Repak ELT are the Approved Body tasked with tracking and monitoring all such activity.
Part 2 of the Third Schedule in the tyre Regulations outlines the reporting requirements for Retailers to Repak ELT.
In summary, this covers all tyre purchases, sales and waste tyres collected.
This data is critical to allow Repak ELT to track and monitor all tyres through the supply chain and to offer collection of waste tyres from all compliant members on a 1 for 1, like for like basis.
If a member fails to report correctly it may result in having their collections suspended until issues are addressed.
Any business that places tyres onto the Irish market for the first time is defined as a ‘Producer’ and this is a subset of Retailers. These tyres can be in the form of replacement tyres or as parts attached to vehicles and implements.
If you are a Producer then you are required to report every month all tyres sold from an imported source to the PRL, as well as the following to Repak ELT:
· All local purchases from Republic of Ireland-based suppliers.
· All purchases from outside the Republic of Ireland as bought from themselves.
· Any tyres which the Producer may have fitted to a vehicle but which the Producer did not actually sell.
· All tyres sold to trade (B2B) and General Public (B2C)
Waste Tyres Collected:
· All waste tyres collected
Tyres with zero rated vEMC must also be reported
You are obligated for all reporting and fees arising from the start of the Repak ELT tyre compliance scheme (October 1st 2017) regardless of when you join.