RecyBEM: waste management contribution on caravan tires
Since April 1, 2004, a mandatory waste management contribution applies to car tires. The fact that this has also applied to caravan (and trailer) tires since 2007 is now known to most entrepreneurs in this sector. Nevertheless, a mailing from RecyBEM at the end of 2020 once again shook up many entrepreneurs in this area.
RecyBEM is a collection and processing system set up by De Vereniging Band en Milieu (The Tire and Environment Association). Collected tires are processed in an environmentally responsible manner and find a new life in numerous applications. A number of companies were not entirely aware of the fact that the RecyBEM system was declared generally binding (AVV) in 2015 and that this also has consequences for them.
Since 2007, producers and importers of caravans and trailers have fallen under the Car Tire Management Decree. This means that importers of caravans and trailers are also responsible for the collection and environmentally sound processing of discarded tires. Since July 2015, they have been doing this by paying the statutory waste management contribution for the tires to the Stichting Fonds Band en Milieu (Tire and Environment Fund Foundation). RecyBEM thus organizes the collective collection and processing. In this way, this sector also contributes to the costs of collecting and recycling car tires.
From the industry
In the magazine BEM-circle, a number of entrepreneurs from the industry have talked about their environmental contribution. Such as Van der Slik Caravan Centrum Zoetermeer, for whom the contribution has been a matter of course since 2008: “At the time, I didn't think I was importing anything. I sold caravans that – I assumed – were imported by another party. Did I have to consider those tires as a separate import product and pay a contribution for them? What a hassle, I thought then. After some explanation, I accepted that. I started to fulfill my obligation properly.”
Van der Slik Caravan Centrum notes that some brands – such as Adria – make it easy for him by taking care of the administration and payment. “With Caravelair, I have to do it myself. That's also okay, just like the procedure for the recycling contribution for refrigerators. Once a year, I report to an authority how many refrigerators were in the imported caravans – I don't feel like a refrigerator importer, but I participate properly.”
“Just like every entrepreneur also pays for Buma/Stemra and for reprographic rights. My daughter arranges the tire statement every month and once a year we check if the total is correct and adjust it if necessary,” says the Zoetermeer company, which suspects that there is no unwillingness among companies that did not do so yet. According to them, this is about not being aware of the existence of a legal obligation.
Taking it on themselves
That also applied to Van Uden Caravans in Sint-Oedenrode: “Since November, I have been a board member of BOVAG, caravan and camper division. It came up at a board meeting. Only then did I realize that I had to take on that contribution myself. I think that many caravan companies, like us, did not feel addressed all this time. After all, as dealers for the import of caravans, they work through agents. Now it turns out that they wrongly assumed that the contribution was not their responsibility. That was also the case with us.”
Van Uden Caravans has been importing brands from Germany (Bürstner), France (Sterckeman) and the UK (Sprite) for years, the first through Erwin Hymer Group, the latter two through Caravan Trading Europe. When it became clear that they had to take action, they were initially surprised. “Not so much about the payment, it's not about the principle here. It's more about: why us and not the agent who, in our opinion, actually does the import.”
Who is responsible?
According to the Car Tire Management Decree, the agent is not the importer; the importer is the person under whose responsibility, in the exercise of his profession or business, car tires, caravans, and trailers are brought into Dutch territory and are made available to another person for the first time in the Netherlands. An agent usually does not acquire ownership, which means that he is not the one who sells the caravan to another person for the first time.
In the meantime, Van Uden Caravans has registered with the BEM and will also file a retroactive declaration from July 2015 for the tires that have ended up on Dutch roads via this company. “That's still a practical thing, because between 2015 and now we switched to a new administration package and I can no longer access the old system. But with a little goodwill, I can trace the invoices, count the numbers, and arrange the declaration and payment. That will be fine.”
Erwin Hymer Group
Good news for all dealers of the brands Bürstner, LMC, Eriba and Dethleffs: the Erwin Hymer Group NL has decided to arrange the payment of the waste management contribution for car tires for their Dutch dealers, as a representative of all dealers, as of August 1, 2021. Have you received and been invoiced for caravans of these brands or other caravans from abroad before this date? Then you must submit the declaration for the payment of the waste management contribution for car tires yourself.
Adria: debt repaid
Meanwhile, many entrepreneurs in the industry are already a step further. At importer Adria Benelux, the retroactive declaration has also been arranged. “With that, we have, as it were, ‘repaid our environmental debt’. Actually, the declaration was arranged so easily, a matter of counting and the total times the contribution. We have decided that the declaration should also be our task from now on and not that of the dealers. We have informed our dealers that they will not have to worry about it administratively. Logical, because we are the importer.”
At Adria, they always thought that the obligation only applied to motorized vehicles. “That's why we've been paying the contribution for motorhomes for years, but not for what you could count under the 'trailers' group. Maybe we should have looked into that a bit earlier. The signal that Band & Milieu gave us made us think. We have joined the Vereniging Band en Milieu. As it should be.
Questions from RecyBEM
Not all companies are aware of the obligation to pay the statutory waste management contribution for car tires. RecyBEM has therefore drawn up a number of questions to clarify whether a company must pay the statutory waste management contribution for car tires.
- Do you purchase new or used car tires abroad from companies that are not members of the Tire and Environment Association?
2. Do you buy car tires from websites of companies not based in the Netherlands? (Even if websites are in Dutch, they may be from foreign companies)
3. Do you receive car tires, caravans or trailers from abroad or are you invoiced from abroad?
4. Do you produce or assemble caravans or trailers and purchase the tires abroad from non-BEM members?
5. Do you import cars, campers or commercial vehicles with an extra set of car tires?
6. Do you sell car tires from scrapped cars?
7. Are you the first to bring car tires to the replacement market in the Netherlands?
Is the answer to one of these questions 'Yes'? Then contact RecyBEM: www.recybem.nl
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