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RoHS & WEEE

 

RoHS and WEEE Compliance

RoHS

The costs of compliance are high.
By some estimates, the average electronics manufacturer with $500 million in revenue will spend $10 million in RoHS compliance. The responsibilities of compliance are even greater. In Europe, original equipment manufacturers (OEMs) will have cradle-to-grave responsibility for their products, having not only to collect and recover all non-compliant products, but also to pay for the treatment and recycling of all affected products. This applies not only to manufacturers in Europe, but to those who sell products in the EU.

Some exemptions have been granted because, to date, no substitute materials are available.
For example: lead in the glass used for cathode ray tubes.
The list of exemptions will be modified to adapt to scientific and technical progress.

The RoHS Directive applies to

Equipment in the following categories:
Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment
Lighting equipment (including electric light bulbs and household light fixtures)
Electrical and electronic tools, except large-scale stationary industrial tools
Toys, leisure and sports equipment
Automatic dispensers

The RoHS Directive does not apply:

  • To large-scale stationary industrial tools.
  • To spare parts for the repair or reuse of EEE placed on the market before 1 July 2006.
  • To equipment relating to protection of the essential interests of state security, weapons, ammunition and military equipment designed for specifically military purposes.

UK Government RoHS Home Page

WEEE Regulations

Waste Electrical & Electronic Equipment (WEEE)

EC Directive on Waste Electrical and Electronic Equipment (WEEE)


The Waste Electrical and Electronic Equipment Directive  (WEEE Directive) aims to minimise the impact of electrical and electronic goods on the environment, by increasing re-use and recycling and reducing the amount of WEEE going to landfill. It seeks to achieve this by making producers responsible for financing the collection, treatment, and recovery of waste electrical equipment, and by obliging distributors to allow consumers to return their waste equipment free of charge.


The Waste Electrical and Electronic Equipment (WEEE) Directive was agreed on 13 February 2003, along with the related Directive on Restrictions of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS).
The implementation of the WEEE Directive in the UK has been delayed.  It was due to be transposed into Member State legislation by 13 August 2004 and come into force by 13 August 2005.   
The UK Regulations implementing the WEEE Directive were laid before Parliament on 12 December 2006 and enter into force on 2 January 2007.  Non-Statutory Guidance will be available in the new year.

3. The WEEE Directive is a wide-ranging piece of European environmental legislation. It is one of a small number of European Directives which implement the principle of "extended producer responsibility". Under this principle, producers are required to take financial responsibility for the environmental impact of products they place on the market, especially when those products become waste. The WEEE Directive applies this principle in relation to electrical and electronic equipment (EEE).

 

Who needs to consider WEEE?

A producer putting electrical and electronic equipment (EEE) within the scope of the WEEE Regulations onto the UK market.

You are a producer for the purposes of the WEEE Regulations if you are:

  • a manufacturer of EEE, selling under your own brand in the UK; or

  • a business based in the UK selling under your own brand EEE manufactured by another person; or

  • a professional importer introducing EEE to the UK market; or

  • a business based in the UK that places EEE in other European Members States by means of distance selling.

If you are a producer, you have several obligations under the WEEE Regulations:

You must join a Producer Compliance Scheme (PCS) to discharge your obligations as a producer of EEE, for example, registering as a producer, reporting data on EEE you put on the UK market, and financing any costs of collection, treatment, recovery and disposal of WEEE in line with your notified obligation;

you must ensure the marking of EEE you put onto the UK market to assist with its separate collection at the end of its life. You must make information available to treatment facilities in respect of new types of EEE you put on the UK market.

A distributor of EEE in the UK.

You are a distributor (irrespective of selling technique) for the purposes of the WEEE Regulations if you are:

  • a retailer of new EEE; or

  • a wholesaler of new EEE;

If you are a distributor selling new EEE to householders, you have obligations under the WEEE Regulations.

Distributors have an important role to play in facilitating the take back of WEEE from householders.

The main obligation on distributors is to provide a take-back service to householders enabling them to return their WEEE free of charge. The WEEE Regulations provide you with a choice of providing "in-store" take-back or participating in the Distributor Take-back Scheme, or providing an alternative system for free take-back for householders. There is a further obligation on distributors to provide householders with information on the options that are available to them for the free return of their WEEE and on the environmental benefits resulting from its separate collection.

 

General guidance on the types of products that may be outside the scope of the Regulations

The WEEE Directive provides for a number of exemptions from its  provisions for a broad range of products and equipment. These exemptions are reflected in the UK WEEE Regulations.

EEE intended to protect national security and for military purposes...

There is an exemption for EEE intended specifically to protect national security and/or for military purposes. However, this exemption does not apply

Electrical and electronic equipment that is part of another type of equipment...

The WEEE Directive excludes EEE that is part of another type of equipment that does not fall within the scope of the WEEE Directive. Examples of such equipment would be lighting or entertainment equipment for use specifically in vehicles, trains or aircraft.
Equipment specifically designed to be exclusively installed on airplanes, boats, cars and other forms of transport is considered to be outside scope. For example, a satellite navigation kit designed to be permanently installed in a car would be exempt, but it may be subject to the requirements of the End-of Life Vehicles Directive.

Equipment may also be part of a fixed installation...

A “fixed installation” may be a combination of several pieces of equipment, systems, products and/or components (or parts) assembled and/or erected by a professional assembler or installer at a given place to operate together in an expected environment and to perform a specific task, but not intended to be placed on the market as a single functional or commercial unit.

In such a case, the elements of a system that are not discernible EEE products in their own right or that do not have a direct function away from the installation are considered to be excluded from the scope of the Regulations.

Large-scale stationary industrial tools...

This is a machine or system, consisting of a combination of equipment, systems, products and/or components installed by professionals, each of which is designed, manufactured and intended to be used only in fixed industrial applications.

Household luminaries...

It should be noted that luminaries used in nonhousehold environments, such as commercial premises, are within the scope of the WEEE Regulations.

Filament light bulbs...

This exemption applies to all light bulbs that emit light through the use of a filament.)

All implanted and infected medical devices...

The WEEE Directive requires medical devices generally (Category 8 equipment) to be treated at end-of life, but not recycled or recovered to target levels. This is reflected in the WEEE Regulations.

 

Key dates...

2 January 2007: WEEE Regulations come into force

31 January 2007: Deadline for compliance schemes to apply for approval

15 March 2007: Deadline for producers to join a compliance scheme

31 March 2007: Deadline for compliance schemes to register producers with environment agencies

in England, Northern Ireland, Scotland and Wales

1 July 2007: Start of first compliance period

31 December 2007: End of first compliance period

 

What you need to do...

Register with a compliance scheme

Every company in the UK that manufactures, imports or re-brands electrical and electronic equipment (known as EEE1) is called a producer and must join an approved producer compliance scheme by 15 March 2007.
To do this you will need to pay a registration fee to the scheme and supply data on how much electrical and electronic equipment you place on the market each calendar year. You also need to say whether you supplied the equipment for household or business use.
You will get a WEEE producer registration number that you will need to give to anyone who distributes or sells your equipment.

 

Government WEEE Guidance Notes

UK WEEE Regulations

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