WEEE COMPLIANCE SERVICES

Tel. +1 (514) 887-7871


WEEE CONSULTING SERVICES

Waste of Electrical and Electronic Equipment

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

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, 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?

e-waste WEEE
  • 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, and POP efforts, the quantities of electronic waste tend to increase years after years.  This tendency is caused by mass consumption of devices.
  • Still, in our days, the vast majority of electronic waste collections methods are not even documented.
  • Too many quantities of e-waste end up in landfills, are illegally exported and are not safely recycled.

What does it Mean to be WEEE Compliant?

WEEE label symbol
Crossed out wheelie bin

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 requests 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.
  • 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.

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

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.

  • 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

WEEE Conformity

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 are drafted towards the producer's full responsibility for the waste management of its products.

Contact Enviropass for further assistance on WEEE!

Enviropass Expertise Inc.

Suite 211 - 1750 St-Louis

Montreal, H4L 5N4, Quebec, Canada

Tel: +1 (514) 887-7871