Dear Tomas,

Thank you very much for your email. Especially for the commentary about the EPA and EIGO issues.
I have discussed this with my colleagues and here are my additional questions to you in order to get the
broader view of this situation:
1. Are there only two potential contractors in Lithuania (EPA and EGIO)? Is there possibly a third
company with which we could contract that does not have such complications?
Unfortunately, in Lithuania there are only two potential contractors of which you can choose. In present, the
licence of EPA is abolished, which means that the contract can be signed only with EGIO.
2. Would it be better (if possible) for MK Lithuania to handle the registration directly, instead of going
through a contractor?
Yes, it would be much better if the contract would be signed by your local branch.
3. It seems that EPA may not have been directly implemented in the wrongdoing; rather, it was EPAs
recycling partner. Is that correct? If so, what exactly is EPAs involvement? Has EPA itself been implicated
in any illegal activity? Does EPA have multiple recycling partners? Does EGIO use the same recycling
partner as EPA?
EPA has problems of two kinds: with the providers of services waste managers, because they improperly
managed waste, and with operation of their company. Regarding an official information EPA was warned
three times because of unmanaging to match conditions of the licence and consequently the licence was
abolished. On the other hand, EPA had a number of proceedings against the environmental institutions last
few years, but EPA had won them. Therefore, the matter of legal activity of EPA is debatable.
EPA has some partners who provide the waste management services, but the problem is not in the partners.
The problem is because of situation in the market. Some of electrical and electronic equipment waste cannot
be collected and managed, because there is not enought of them. As we know EGIO has contracts with two
waste managers who provides them services of electrical and electronic equipment waste management. One
of them is the same as EPAs, another has a poor reputation, because of the lawsuit where they are suspected
of fraud in waste management.
3. Did EPA change their recycling partner after 2013? If EPA has a new recycling partner, does that
mitigate the risk going forward?
We do not have an exact information regarding this matter, but as we know the providers of waste
management in EPA have been the same few last years.
5. What is the risk to MK Lithuania is a registration is suspended or annulled? If this happens, can MK
Lithuania simply re-register and be considered compliant with the regulations? I understand that annulment
would cause additional administrative expenses, but does it expose the company to legal risk, if it happens?
MK registration in Lithuania cannot be annulled. The company could be annulled only if the company asked
to be abolished from the list of manufacturers and importers. The registration shows that MK is manufacturer
and (or) importer of electrical and electronic equipment waste. Therefore, the company has an obligation to
control EEE waste and participate in the organisation, which technically manages EEE waste.
As I know, MK has been operating for some years without any registration and contracts with organisations
in Lithuania. Therefore, I suggest that it should operate without registration and look what will happen in the
market. While speaking about that, these aspects of the matter are significant:

As MK is not registered, the competent governmental institutions have no posibilities to understand that MK
is an importer which has to manage EEE waste. The fact of being manufacturer or importer could be clarified
only if the concrete study on companies which operates non-registered would be started.
If the mentioned institutions will find out that the company has no registration, the manager of the company
would have to pay the fine from 2700 to 6000 euros (usually, the lower fine must be paid). In addition, there
is a possibility that the company should have to manage the amount of waste which had to be managed for
the last (non-registered) years.
If MK operated and has not managed EEE waste for several years, in the momento f registration the
governmental institutions could find out that and the same fine and other remedies would be executed. In the
other words, the registration increases posibility of finding out that the waste were not managed.
If MK does not want to wait and risk, there is only one posibility to cope with the problem to sign a contract
with EGIO, but, as it was said in the last few letters, the reputation of EGIO is not good as it could be,
because some of EGIO providers of services are suited.

Thank you,