Large hardship application

A large hardship application can relate to fees according to the fee-related matters number 1.1, 1.4-1.7, 1.15, 2.1, 2.3, 3.1 as well as 3.2 in the list of fees as appendix 1 on § 1 ElektroGBattGGebV. Besides the fees for guarantee or prima facie evidence examination there are further fees, especially such for processing registration applications or the examination of the participation in a collection scheme für producers of batteries. 

For this application stiftung ear examines on the basis of four criteria whether the fee collection is dispropotional. Please therefore submit documentation with your application in which the following is clear:

  • amount of batteries or electrical and electronic equipment placed on the market
  • economic value of the registration for the producer
  • predicted disposal costs
  • waste managemental relevance of the batteries or electrical and electronic equipment

Because in this case all four criteria are to be weighed against each other, a fee may be reduced as a result if individual points speak for, but others speak against the disproportion of the fee(s). In contrast to the small hardship application, neither exceeding a threshold value, nor the non-submission or late submission of an amount report automatically leads to the application being rejected. But stiftung ear requires conclusive documents on all four criteria to be able to decide upon the application. If the necessary documents are not or not completely submitted then the application must be rejected due to insufficient basis for decision-making.

Please submit the application online in the ear-portal. There you can upload any necessary documents. It is not necessary to send in original documents. 

Further Information

You find the ElektroGBattGGebV in its legally effective version at.