RecyBEM: waste management contribution on caravan tires
Since April 1, 2004, a mandatory waste management contribution applies to car tires. That this has also applied to the tires of caravans (and trailers) since 2007 is now known to most entrepreneurs in this sector. However, a mailing from RecyBEM at the end of 2020 once again woke up many entrepreneurs in this area.
RecyBEM is a collection and processing system set up by the Band and Environment Association. Collected tires are processed in an environmentally responsible manner and find new life in numerous applications. A number of companies were not fully 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, manufacturers and importers of caravans and trailers have been subject to the Car Tire Management Decree. This means that importers of caravans and trailers are also responsible for the collection and environmentally responsible processing of waste tires. Since July 2015, they have been doing this by paying the statutory waste management contribution for the tires to the Tire and Environment Fund Foundation. RecyBEM organizes the collective collection and processing. This sector also contributes to the costs of collecting and recycling car tires.
From the industry
A number of entrepreneurs from the sector have told something about their environmental contribution in the magazine BEM-circle. Like Van der Slik Caravan Centrum Zoetermeer, for whom the payment has been a matter of course since 2008: “At the time I had no idea that I was importing anything. I sold caravans that – I assumed – were imported by another party. Should I view those tires as a separate import product and pay a contribution on them? What a nonsense, I thought at the time. After some explanation I accepted that. I have properly fulfilled my obligation.”
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. “At 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 as every entrepreneur also pays for Buma/Stemra and for repro rights. My daughter arranges the tire declaration every month and once a year we check whether the total is correct and correct it if necessary," says the Zoetermeer company, which suspects that there is no reluctance among companies that have not yet done so. According to them, this is about not being aware of the existence of a legal obligation.
Pick it up yourself
This also happened at Van Uden Caravans in Sint-Oedenrode: “I have been a board member of the BOVAG, caravan and camper companies department, since November. It came up at a board meeting. Only then did I realize that I had to pick up the payment myself. I think that many caravan companies, like us, felt ignored all this time. After all, they work as a dealer for the import of caravans through agents. It now appears that they wrongly assumed that the payment was not theirs. That's how it was with us.”
Van Uden Caravans has been supplying brands from Germany (Bürstner), France (Sterckeman) and the UK (Sprite) for years, the first through Erwin Hymer Group, the last two through Caravan Trading Europe. When it became clear that they had to take action, they were initially surprised. “It's not so much about paying, it's not about the principle. It is more about: why us and not the agent who, in our opinion, actually does the importing.”
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 the first to be made available to someone else in the Netherlands. . An agent usually does not acquire ownership, so he or she is not the first to sell the caravan to someone else.
In the meantime, Van Uden Caravans has registered with the BEM and they will also report retroactively from July 2015 on the tires that ended up on Dutch roads through this company. “That is still a practical thing, because between 2015 and now we have switched to a new administration package and I can no longer use the old system. But with a little good will I can track down the invoices, calculate the numbers and arrange the declaration and payment. It is going to be okay."
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 of August 1, 2021, as a representative of all dealers. Have you received and invoiced caravans from these brands or other caravans from abroad before this date? Then you must submit the declaration for payment of the waste management contribution for car tires yourself.
Adria: debt paid
In the meantime, many entrepreneurs in the industry have already taken a step further. The retroactive declaration has now also been arranged at importer Adria Benelux. “We have thus paid off 'our environmental debt', so to speak. In fact, the declaration was arranged this way, a matter of counting and multiplying the total by the contribution. We have decided that from now on, reporting should be our task and not that of the dealers. We have informed our dealers that they will not have to worry about this in an administrative sense. Logical, because we are the importer.”
At Adria they always thought that the obligation only applied to motorized vehicles. “That is why we have been paying for campers for years, but not for what you could count among the group of 'trailers'. Maybe we should have looked into that a little earlier. The signal that Band & Milieu gave us made us think. We have joined the Band and Environment Association. As it should.
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 buy 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 that are not located in the Netherlands? (Although websites are in Dutch, they may belong to foreign companies)
3. Do you receive car tyres, caravans or trailers from abroad or are you invoiced from abroad?
4. Do you produce or assemble caravans or trailers and do you buy 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 tires from scrap cars?
7. Are you the first to introduce car tires to the replacement market in the Netherlands?
Is the answer to any of these questions 'Yes'? Please contact RecyBEM: www.recybem.nl
Wide range
Still looking for a new or second-hand camper or caravan? We have a large offer that you can choose from from dealers and private individuals. Or would you rather watch the last one first? camping news?
