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WEEE for Beginners

15 June 2007

It has been a long time coming but finally the WEEE Directive will come into force next month. Mark Carter provides a clear and concise explanation of preparations and actions needed by every organisation that generates electrical and electronic waste

DOES FAMILIARITY BREED CONTEMPT? For years the Waste Electrical or Electronic Equipment (WEEE) Directive has been an ‘imminent’ piece of legislation. Over that time we have become accustomed to its name and presence just like some distant relative we have never met but everyone talks about. However, on the 1 July 2007 all that will change when full implementation of the WEEE Regulations takes place across the UK. Now is the last opportunity to really get to know about the Regulations before they come visiting next month.

The first question to answer is what is WEEE? Waste Electrical or Electronic Equipment are products dependent on electricity of less than 1000 volt AC (or 1500 volt DC) to work properly. Thus if the electricity is switched off, the product cannot fulfil its main function. In addition, if electricity is used only for control or support functions, the product can also be considered to be outside the scope of the WEEE Regulations.

Electrical and electronic equipment (EEE) covered in the Directive is split into 10 main categories which includes:
● Large household appliances (dishwasher)
● Small household appliances (coffee maker)
● IT and telecommunications equipment
● Consumer equipment (TVs, videos, hi-fis)
● Lighting equipment (Household luminaries are not covered by WEEE, but in commercial premises do come within its scope)
● Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
● Toys, leisure and sports equipment (e.g. running machines)
● Medical devices (except of all implanted and infected products)
● Monitoring and controlling instruments
● Automatic dispensers

However, there are some items that are exempt from the WEEE Regulations. Such as:
● Filament light bulbs
● Large-scale, stationary industrial tools (a machine or system installed by professionals, which is designed manufactured and intended to be used only in fixed industrial applications).
● Spare parts, as they are not products by themselves. Therefore a spare for a photocopier is not WEEE, but the complete machine is.
● Electronic components that are not needed to fulfil their primary function (soft toys with electronics inside or musical greeting cards.)
● Medical devices that are implanted and/or infected products.

The lists above are not comprehensive and cannot be exhaustive. They are examples of items that a facilities manager may well have under his/her responsibility. As with all new and existing legislation, if you have any doubts please seek expert help in resolving the issues. All WEEE products should be identified with a ‘crossed out wheelie bin’ symbol. This symbol on the product or on its packaging indicates that this product must not be disposed of in normal household waste.

Q: Now it is possible to identify WEEE, the key question has to be “why do you need special regulations for it?”
A: Although the RoHS (Restriction of Hazardous Substances) Directive came into force on 1 July 2006, much of WEEE often contains many hazardous substances, such as lead or cadmium.

WEEE is also the fastest growing waste stream both in the UK and EU. It is reported to be growing by 8 per cent/year, and totals an average of 14kg a person, 90 per cent of which goes to landfill or incineration.

The main aim of the Directive is to address the environmental impacts of electrical and electronic equipment (EEE) when it reaches the end of its life by reducing the amount of WEEE going to landfill or incineration. It also aims to increase rates of re-use, recovery, recycling and environmentally sound disposal. Targets are set out in the Directive for each product category eg: To achieve this it requires all manufacturers and producers to take responsibility for what happens to the products they sell at the end of their lives. (NB: It states ‘sell’ and not ‘make’, so this encompasses importers, distributors and retailers as well an actual manufacturers. WEEE was conceived to improve the environmental performance of all operators involved in the life cycle of electrical and electronic equipment.)

Q: As facilities managers we don’t manufacture EEE. How will the full implementation taking place on the 1 July 2007 affect me and what needs to do under these regulations?
A: WEEE should be treated as part of your larger waste management and recycling system. As with any good management system, it would be good practice to first designate a person responsible for WEEE. This well may be the FM, but someone from IT (the main producer of WEEE) is also a likely candidate. It is a necessary first step that all WEEE should be identified, collected and stored separately. Once you know what you’re dealing with, it will help clarify which course of action you next take.

Three options
Essentially there three main options available for you to dispose of WEEE:
Option 1: You can reuse, resell or donate it, an ideal solution for some items such as IT equipment. This can offer a cost saving with cannibalisation of equipment, a potential source of income or good PR when donating to charity. However, if this involves export from the UK you should consult the relevant environment agency to establish whether the equipment would be considered to be waste at this time and therefore subject to controls.

Option 2: The Take-back Option. If you are replacing EEE purchased after 13 August 2005, with equivalent equipment, businesses can get the suppliers of the new item to take away the old on a free of charge, one-for-one basis. Ideal if upgrading existing equipment or replacing failing and broken equipment.

Option 3: The DIY option comes into operation under following circumstances.
● If you are unable to trace the original provider.
● Have historic (ie: purchased before 13 August 2005) WEEE, and /or have equipment that is not being replaced
● If you negotiated with your supplier to accept the costs of disposing of treating any WEEE.

You will have to arrange and pay for, disposal yourself using a registered waste contractor. It may be possible to negotiate with your supplier for the disposal of any additional WEEE that is over-and-above the direct equivalent replacement number. If agreed, it may be convenient, but not necessarily cost effective.

If your company produces substantial amounts of WEEE, it may be worth dealing directly with an authorised treatment facility (ATF) for treatment, recycling or environmentally sound disposal. For many commercial businesses the most common approach is to use a registered waste contractor to deal with their WEEE. This can be difficult for small companies and those producing very little waste electrical and electronic equipment. Contactors may have minimum weight restrictions that means you have to store WEEE a long time between collections. One possible solution is to combine with others is a similar position and deal with the contactors as a local co-operative.

Q: Is there anything else that needs to be done about implementing WEEE?
As with other areas of compliance, businesses are required to obtain and keep records. This is to demonstrate that their WEEE was treated and/or disposed of in an environmentally sound way. It is also important that you communicate the policy on WEEE to all your staff. This should include ways to identify WEEE, the special procedures associated with its collection and separation plus any other variance in dealing with normal waste streams.

When selecting a registered waste contractor ask them for their relevant waste management licences/permits. In addition, check their policies on data protection and security, and always ensure any corporate data held on the equipment is removed or erased prior to disposal.
Q: What are the penalties for failing WEEE compliance?
A: Failure to comply with the regulations can result in a fine. If dealt with by Magistrates they are limited to a maximum fine currently of £5000. If in a Crown Court there is no limit to the fine that can be imposed.

Q: I am in a multinational organisation. Is the WEEE Directive effective across the EU?
A: The UK was not alone in being slow to implement the WEEE directive. In fact Greece was the only EU member state to meet the 2004 deadline. However, most of the rest of Europe has been much more proactive when it comes to implementing WEEE.

No obligations are placed on local authorities by the WEEE Regulations 2006. However, the UK Government recognises that they will need to build on our existing waste management infrastructure in order to comply with the requirements of the WEEE Directive.

The information given here offers only a brief outline of WEEE from the FM/ business users point of view. The requirements of the legislation differs considerably for producers and sellers of Electrical or Electronic Equipment. If you are unsure about WEEE, get specialists to help guide and assist you. Experts can often help provide the best solution and often offer ways to save money.


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