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Are you
ready to stay legal and join a DTI approved WEEE producer compliance scheme and
ensure that you fix your cost for remaining legal?
For all of
you who are struggling to understand the WEEE directive and your
responsibilities I will attempt to explain the WEEE directive and your legal
responsibilities in simple terms.
Am I a
producer?
If you
build or rebadge new equipment that you then sell you are a producer.
(WEEE is
classified as whole items that use electricity and the producer is the person
who first sells the item.)
I only
repair or upgrade computers, am I a producer?
NO under the WEEE directive and the DTI guidance if you
replace a component in the course of a repair or upgrade to a computer then you
are not classed as the producer. Also if you repair and then sell second hand
equipment you are not a producer and have no responsibilities under the WEEE
directive.
I only
sell branded products and computers does this make me a
producer?
NO if you resell only branded products as manufacture
supplied unaltered products then you are not a producer and do not have to join
a WEEE producer compliance scheme. You will have to join a
Distributor take back scheme or offer some form of in-store take back service.
We are able to provide in store or private take back schemes for any customers
preferring to collect from their customers and arrange the recycling themselves.
If I lease rather than sell the
EEE I produce, am I still a producer?
Yes, since
you would still be regarded as putting EEE on the market.
If I only provide the finance
arrangements for the leasing of EEE am I a
producer?
No - those organisations that
exclusively provide financing arrangements for EEE are not producers under the
WEEE Regulations.
Hopefully
you will now be able to decide if you need to join our WEEE producers compliance
scheme or not so we have outlined below the other legal requirements you will
need to comply with.
The
WEEE Directive Producer Requirements
The Regulations require you to
report the weight of EEE in tonnes that you place on the UK market. You should
include the weight of the whole electrical or electronic product itself, any
electrical or electronic accessories supplied with it, and any non-electrical
accessories that are specific to the product or likely to be regarded by the
purchaser as part of the overall product and therefore likely to be discarded
with it. You should not include packaging, instructions and other paperwork.
For example:
The weight of a power drill
should include the power lead and or/battery pack and any fitted storage or
carry case, chuck key, accessory handles or battery chargers, but not the
cardboard box or sleeve and protective padding, manual or drill bits.
The weight of a food
mixer/processor will include the power lead, mixing bowls, cutters, beaters,
pushers, lids or stands but not the packaging or protective padding, manual.
The weight of an electric
kettle should include the kettle itself, the mains lead and any separate stand
but not, packaging and protective padding or manuals.
Summary of producer obligations
under the WEEE Regulations
If you are a producer, you
must:
Join an approved Producer
Compliance Scheme (PCS) that will undertake several actions on your behalf
during your membership. It will register you as a producer with UK authorities,
report the EEE you place on the UK market, arrange the collection, treatment and
environmentally sound disposal of an amount of WEEE deposited at DCFs or
returned under Regulation 32, and declare this, supported by evidence, to the
appropriate authorities. If you enter the UK EEE market after the registration
deadline for a compliance period, you must join a PCS within 28 days.
Pay your Producer Compliance
Scheme according to its published fee structure and membership rules. You
bring to your PCS obligations to finance the collection, treatment, recycling
and environmentally sound disposal for:
a. household WEEE arising in
each compliance period, as the proportion given by your share of the UK market
for EEE in each category; and
b. non-household WEEE arising
in each compliance period, from: EEE you placed on the market on or after 13
August 2005;and in addition
c. EEE that was placed on the
market before 13 August 2005, regardless of the producer, which the user is
replacing withthe equivalent new EEE you provide.
Provide information to
your Producer Compliance Scheme about your business, and on the amounts of
EEE you place on the UK market on a quarterly basis, broken down by compliance
category and its household or non-household nature. Your PCS is required to
report this information to the appropriate authorities (Schedule 6 to the
Regulations lists the information that must be provided).
Mark the EEE you place on
the UK market with the crossed-out wheeled bin symbol and your unique
producer identification mark as reported with your registration. Details of the
crossed-out wheeled bin and date markings can be found in British Standard BS EN
50419:2006 or later. This is available for purchase from BSI online, and may be
available for reference through your public library.
Make information available
to operators of treatment and reprocessing facilities about your new
products, to help with effective treatment, recycling and re-use. This includes
information about the different materials and components of the EEE, and the
location of any hazardous substances. This obligation starts for products first
placed on the market from 1 April 2007, and information must be available within
one year of the EEE being placed on the market.
Provide your producer
registration number to distributors to whom you supply EEE. This confirms to
them that they are purchasing EEE from a registered producer in the UK. You may
incorporate your registration number into your letterhead, or provide it in
writing by other means when EEE is transferred. Your registration number should
remain unchanged between compliance periods, even if you change your Producer
Compliance Scheme, and will be the same for household and non-household EEE.
Retain records for a
period of four years, including of the amounts of EEE you place on the UK
market, broken down by compliance category and household / non-household nature.
Retain records of sales
direct to end users in other Member States, for a period of four years,
including how you have complied with your obligations those other Member States.
How much is this going to cost?
Every producer registered
with the Environment Agency will be charged a fee this will depend on the
turnover of your company. The fees charged for 2007 are given in the Regulations
as:
Non Vat
registered companies - £30
Vat registered,
turnover below £1 million - £ 220
Vat registered,
turnover above £1 million - £ 445
Each PCS will charge a
membership fee and a charge per tonne of WEEE handled. This charge will vary
depending on the Category of WEEE but is set at £6 per tonne for IT and
Telecoms equipment on a B2B Scheme.
We are able to register you
with a producers compliance scheme for the prices set out below.
Annual registration/admin
Fee
Small Producer (Less than 5
tonnes pa EEE output) £230.00
Medium Producer ( 5- 50
Tonnes pa EEE output) £520.00
Large Producer (50 tonnes
Plus pa EEE output) £960.00
If you would like a fixed
cost for recycling of your obligated WEEE this can be arranged for an upfront
payment based on your declared 2006 EEE output figures and would be a price of
between £6 -£40 per tonne.
So for a company building
computers who by weight built <5 tonnes of computers in 2006 with a turnover of
under £1 million the fixed cost for ensuring that they remain legal and
complying with the WEEE directive would be:
EA registration
fee: £220
Compliance scheme
fee: £230
Recycling
cost: £27 (based on 10% waste in year)
Total cost exl vat and cost
of labels etc. £450.00
So for a fixed cost of £450
+ vat you can satisfy your obligations under the WEEE directive without costing
a small fortune unlike other scheme which could end up costing you thousands.
Our Partners WeeeCare are
the only WEEE Producer compliance scheme that we know off who are approved by
the DTI and guarantee a fixed cost for compliance during 2007.
For those companies looking
to environmentally recycle their non obligated WEEE or offer an in store take
back service we can help through our recycling service.
If you would like to discuss
the WEEE directive and your individual situation please feel free to contact us
either by email or telephone 0845 0560537.
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