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WEEE Consulting Services

To help you achieve compliance with the European directive 2012/19/EU and other WEEE-like regulations worldwide, Enviropass is here to:

  • Identify your applicable legal requirements, according to your business model, and show you the different available options for your expansion in Europe.
  • Perform the various legal periodical statements for imported production on your behalf.
  • Train and give you the keys to a perfect command of WEEE regulations
  • Certify your WEEE compliance.
Waste of Electrical and Electronic Equipment

Contact Enviropass for more details on WEEE compliance!

The EU WEEE Directive

  • WEEE stands for Waste Electrical and Electronic Equipment.
  • In the European Union, the WEEE directive  was voted on July 4th, 2012.  It is the Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic equipment.
  • The Directive 2012/19/EU is a recast version which supersedes the previous version: Directive 2002/96/EC.
  • Just like Europe RoHS and REACH SVHC, the objective of the Directive 2012/19/EU is to protect both the environment and human health.
  • Europe RoHS is dedicated to product design while WEEE takes care of the waste. This is a cradle to grave product stewardship approach.
  • WEEE exclusively focuses on the negative impacts of electrical and electronic waste. WEEE aims at reducing or avoiding such impacts, via a more efficient collection and recycling.
  • Every Member State in the European Union has voted its regulation on a national level for the implementation of the WEEE Directive.
  • Other countries worldwide also adopted WEEE like regulations, such as India, provinces of Canada, and many states of the USA.

Why do we Have WEEE Regulations?

  • Tens of millions of metric tons of electronic waste are generated annually worldwide.
  • Due to its complex nature and diversity of materials, it is very hard to recycle electronic waste properly.
  • On top of containing various hazardous substances despite the RoHSREACH SVHC, and Persistent Organic Pollutants efforts, the quantities of electronic waste tend to increase years after years.  This tendency is caused by the mass consumption of devices.
  • Still, in our days, the vast majority of electronic waste collection methods are not even documented.
  • Too many quantities of e-waste end up in landfills, are illegally exported, and are not safely recycled.
e-waste WEEE

What does it Mean to be WEEE Compliant?

The WEEE approach follows the extended producer responsibility (EPR) principle.  If, as a producer or an importer, you introduce in-scope electrical or electronic equipment into the EU market, here is what you need to accomplish:

  • First-of-all, article 15, section 1 of the European WEEE directive requires producers to provide information on re-use, and treatment for recycling of their products, identifying sub-assemblies as well as hazardous chemicals.
  • You must label your products with the crossed-out wheelie bin symbol, preferably in accordance with the European standard EN 50419.
  • Unless you have your own approved collection and recycling system, you will also have to adhere to an authorized Compliance Scheme in every European Union member state where you place in-scope equipment. Some states only have one approved Compliance Scheme while others offer various choices.
  • Furthermore, in many cases, you may have to appoint Authorized Representatives in the member states where you do business, but don’t have a legal entity.
  • You must declare and pay the corresponding fees separately to every national agency in charge of WEEE.  What must be declared is the quantities placed (number of units and weight), per product category.  This needs to be done annually in most states.  However, it can be more frequent in some states, depending on local regulations.  You need to make one set of declarations per member state.
  • Finally, exported EEE data, and sales, should be kept internally for a minimum of 4 years.
Crossed out wheelie bin

WEEE Scope and Product Categories

Under the EU WEEE Directive, the scope is very broad.  It is also very similar to the Europe RoHS one, and includes electrical and electronic equipment falling within the categories set out in annexes I and II:

Product CategoryExamples
1. Large household appliancesMany everyday products, such as fridges, ovens, fans, ventilators, etc.
2. Small household appliancesMany everyday products, such as electric razors, toasters, vacuums, electronic gadgets, etc.
3. IT and telecommunications equipmentHousehold or professional computers, printers, hard drives, cellphones, laptops, screens, etc.
4. Consumer equipment and photovoltaic panelsElectric keyboards, speakers, TVs, solar panels, etc.
5. Lighting equipmentLamps of various types, light dimmers, etc.
6. Electrical and electronic toolsHousehold or professional electric mowers, drills, saws, etc.
7. Toys, leisure, and sports equipmentSlot machines, electric stationary bikes, electronic games, robot toys, etc.
8. Medical devicesElectroencephalograms, respirators, ventilators, defibrillators, dialysis machines, etc.
9. Monitoring and control instrumentsHousehold or professional control panels, sensors, motion detectors, etc.
10. Automatic dispensersVending machines, automated ticket or cash dispensers, etc.

Since August 2018, the EEE are classified according to these six categories instead:

Product CategoryExamples
1. Temperature exchange equipmentFridges, ovens, radiators, air conditioning units, etc.
2. Screens, monitors, and equipment containing screens having a surface greater than 100 cm2Household or professional computers, TV screens, etc.
3. LampsHousehold or professional flashlights, lights, etc.
4. Large equipment (any external dimension more than 50 cm)Luminaires, musical instruments, toys, medical devices, monitoring and control instruments, including professional, etc.
5. Small equipment (no external dimension more than 50 cm)Same as category 4, of smaller size, etc.
6. Small IT and telecommunication equipment (no external dimension more than 50 cm)Cell phones, radio, routers, etc.

Is the WEEE Registration Mandatory for all Manufacturers of Electronic Devices?

Both household and professional products fall under the scope.  There is no de minimis.  As a result, even if you only sell one in-scope product into a specific member state during the year, then you must comply with all of the WEEE applicable requirements.

WEEE exemptions apply to different types of products (as set in article 2), such as:

  • Military equipment;
  • Aerospace equipment;
  • Automotive industry;
  • Large-scale stationary industrial tools and fixed installations. The definition of large-scale must be carefully examined;
  • R&D equipment, like prototypes;
  • Some medical devices, such as implantable medical devices.

Packaging and battery  waste recycling follow the same extended producer responsibility principle as WEEE.  Therefore, if you introduce packages and batteries, you must also make declarations and follow the national compliance schemes requirements.

WEEE-like Regulations in North America

Several places such as Canadian provinces, territories, and US states, have enacted WEEE or e-cycling regulations. For instance:

  • California, New-York, and Texas have so-called e-waste ‘Take back’ programs.
  • In Canada, every producer of in-scope electrical and electronic products must register, declare and pay monthly eco-fees in the applicable provinces, and territories.
  • In Quebec, the WEEE rules apply to manufacturers and suppliers, according to the Regulation respecting the recovery and reclamation of products by enterprises (Q-2, r. 40.1). The Quebec Electronic Product Recycling Association (EPRA-Québec) is responsible for enforcing the regulation.
  • In Ontario, the Regulation for Recycling of Electrical and Electronic Equipment and Batteries under the Resource Recovery and Circular Economy Act (RRCEA), 2016 – ERO 019-0048 Reg. 522/20 aims at the producer’s full responsibility for the waste management of its products.
Canadian Province or TerritoryWEEE-like RegulationIndicative Scope
AlbertaRegulation 94/2004 – Environmental Protection and Enhancement Act – Electronics Designation RegulationConsumer, commercial and industrial
British ColumbiaB.C. Reg. 449/2004 – Environmental Management Act – Recycling RegulationConsumer, commercial and industrial
ManitobaThe Waste Reduction and Prevention Act (C.C.S.M. c. W40) – Electrical and Electronic Equipment Stewardship Regulation 17/2010Consumer
New BrunswickRegulation 2008-54 under the Clean Environment Act (O.C. 2008-180)Consumer, commercial and industrial
Newfoundland & Labrador

Regulation 85/12, Waste Management Regulations, 2003 (Amendment) under the Environmental Protection Act

(O.C. 2012-288)

Consumer, commercial and industrial
Northwest TerritoriesWaste Reduction and Recovery Act – Electronics Recycling Regulations R-071-2015Consumer, commercial and industrial
Nova ScotiaSolid Waste-Resource Management Regulations made under Section 102 of the Environment Act S.N.S. 1994-95,c.1Consumer
OntarioO. Reg. 522/20: Electrical and Electronic Equipment under Resource Recovery and Circular Economy Act, 2016Consumer, commercial and industrial information technology, telecommunications and audio visual (ITT/AV) equipment and lighting
Prince Edward IslandEnvironmental Protection Act – Chapter E-9 Materials Stewardship and Recycling RegulationsConsumer, commercial and industrial
QuébecQ-2, r. 40.1 – Regulation respecting the recovery and reclamation of products by enterprises – Environment Quality ActConsumer
SaskatchewanThe Electronic Equipment Stewardship Regulations – Chapter E-10.22 REG 6 – The Environmental Management and Protection Act, 2010Consumer
YukonO.I.C. 2003/184 Environment ActConsumer, commercial and industrial

Contact Enviropass for further assistance on WEEE!