WEEE COMPLIANCE SERVICES

WEEE Enviropass

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:

Provide WEEE Management Information

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. 

Producers must communicate such information to treatment/recycling facilities, in user manuals, electronically, or online.

This requirement is part of the eco-design compliance of devices.

Mark your devices with the Information Crossed-out Wheelie Bin Symbol

You must label your products with the crossed-out wheelie bin symbol, preferably in accordance with the European standard EN 50419.

Join a WEEE Compliance Scheme

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.

Crossed out wheelie bin

Appoint an Authorized Representative, where Required

Furthermore, in many cases, you may have to appoint Authorized Representatives (AR) in the member states. This requirement may apply where you do business, but don’t have a legal entity.

Let’s take the example of a producer overseas placing direct sales in an EU Member State. Then, this foreign distance seller to end-users may have to appoint an AR. It is the case if the seller does not have a local legal entity in States like:

WEEE Europe map
  • Austria
  • Czech Republic
  • Germany
  • Ireland
  • Italy
  • Poland
  • Portugal
  • Romania
  • Spain
  • Sweden

Send Periodical WEEE Reports and Pay the Eco-Fees

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.

Archive your WEEE Information

Finally, exported EEE data, and sales, should be kept internally for a minimum of 4 years.

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 Category

Examples

1. Large household appliances

Many everyday products, such as fridges, ovens, fans, ventilators, etc.

2. Small household appliances

Many everyday products, such as electric razors, toasters, vacuums, electronic gadgets, etc.

3. IT and telecommunications equipment

Household or professional computers, printers, hard drives, cellphones, laptops, screens, etc.

4. Consumer equipment and photovoltaic panels

Electric keyboards, speakers, TVs, solar panels, etc.

5. Lighting equipment

Lamps of various types, light dimmers, etc.

6. Electrical and electronic tools

Household or professional electric mowers, drills, saws, etc.

7. Toys, leisure, and sports equipment

Slot machines, electric stationary bikes, electronic games, robot toys, etc.

8. Medical devices

Electroencephalograms, respirators, ventilators, defibrillators, dialysis machines, etc.

9. Monitoring and control instruments

Household or professional control panels, sensors, motion detectors, etc.

10. Automatic dispensers

Vending machines, automated ticket or cash dispensers, etc.

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

Product Category

Examples

1. Temperature exchange equipment

Fridges, ovens, radiators, air conditioning units, etc.

2. Screens, monitors, and equipment containing screens having a surface greater than 100 cm2

Household or professional computers, TV screens, etc.

3. Lamps

Household 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 US states, Canadian provinces, and territories have enacted WEEE or e-cycling regulations.

Take Programs and E-waste Management in the USA

About half of the US States have so-called e-waste ‘Take back’ programs to manage electronic waste. Similar to the European Union, most e-waste legislation in the USA follows the extended producer responsibility (EPR) principle. As a result, producers will collect and treat e-waste at their own expense. E-waste rules apply to certain product categories (mostly consumer equipment), like:

E-Waste USA
  • California (eco fees applicable to consumers),
  • Connecticut,
  • Illinois,
  • Maine,
  • Michigan,
  • Minnesota,
  • Missouri,
  • New Jersey,
  • New York City and State (some professional products included in the e-waste laws scope),
  • North Carolina,
  • Oklahoma,
  • Oregon,
  • Pennsylvania,
  • Rhode Island,
  • South Carolina,
  • Texas,
  • Vermont,
  • Virginia,
  • Washington,
  • West Virginia,
  • Wisconsin.

WEEE Regulations in Canada

  • 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 Territory

WEEE-like Regulation

Indicative Scope

Alberta

Regulation 94/2004 - Environmental Protection and Enhancement Act - Electronics Designation Regulation

Consumer, commercial and industrial

British Columbia

B.C. Reg. 449/2004 - Environmental Management Act - Recycling Regulation

Consumer, commercial and industrial

Manitoba

The Waste Reduction and Prevention Act (C.C.S.M. c. W40) - Electrical and Electronic Equipment Stewardship Regulation 17/2010

Consumer

New Brunswick

Regulation 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 Territories

Waste Reduction and Recovery Act - Electronics Recycling Regulations R-071-2015

Consumer, commercial and industrial

Nova Scotia

Solid Waste-Resource Management Regulations made under Section 102 of the Environment Act S.N.S. 1994-95,c.1

Consumer

Ontario

O. Reg. 522/20: Electrical and Electronic Equipment under Resource Recovery and Circular Economy Act, 2016

Consumer, commercial and industrial information technology, telecommunications and audio visual (ITT/AV) equipment and lighting

Prince Edward Island

Environmental Protection Act - Chapter E-9 Materials Stewardship and Recycling Regulations

Consumer, commercial and industrial

Québec

Q-2, r. 40.1 - Regulation respecting the recovery and reclamation of products by enterprises - Environment Quality Act

Consumer

Saskatchewan

The Electronic Equipment Stewardship Regulations - Chapter E-10.22 REG 6 - The Environmental Management and Protection Act, 2010

Consumer

Yukon

O.I.C. 2003/184 Environment Act

Consumer, commercial and industrial

Contact Enviropass for further assistance on WEEE!