Hardship application

A 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 on § 1 ElektroGBattGGebV. These are the fees for checking registration applications according to ElektroG and BattG, as well as other services in connection thereof (e.g. guarantee and prima facie evidence checks for producers of electrical and electronic equipment, or checking of the installation and operation of a take-back system for battery producers.) 

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). To be able decide upon the application stiftung ear requires conclusive documents on all four criteria. 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.