Frequently Asked Questions

  • 1. Introduction

    This FAQ sheet is designed to help those who might be affected by the WEEE Regulations to understand how they will work. The Regulations came into force on 2 January 2007 with the first compliance period being 1 July – 31 December 2007. A consultation has recently been issued to make minor amendments to the Regulations and the EU has recently issued proposals to radically change the Directive from which the Regulations were transposed although it is unlikely these will start until 2012 at the earliest.

    The first and second (1 Jan – 31 Dec 2008) compliance periods passed relatively smoothly although there were – and remain – issues about over and under collection by schemes and the resulting trading problems. However, generally the system is considered a relatively fair way of discharging the EU Directive requirements at a reasonable cost to producers.

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  • 2. Summary

    The Regulations are aimed primarily at household WEEE. In simple terms, the Regulations require producers to foot the bill for the collection, treatment and recycling of household WEEE from Designated Collections Facilities (DCFs) which are primarily Local Authority Civic Amenity sites. Producers have to join a Compliance Scheme and provide quarterly data on sales which will be submitted to the Environment Agency (EA) to calculate a market share for each scheme in relation to each of 13 categories. Schemes have to estimate the amount of WEEE that will end up being collected during the compliance period (1 Jan – 31 Dec each year) from DCFs and contract with sufficient Local Authorities to meet their market share to allow the scheme to collect WEEE from their DCFs. Household WEEE collected by retailers is also included in calculating and offsetting market share. Market shares for schemes are calculated by summing the EEE placed on the market in a period by their members in each category and dividing it by the total EEE placed on the UK market during the period in each category. This will then be applied to the total weight of WEEE collected by category over that period to give each scheme an actual weight of WEEE evidence it will need to have to comply for that compliance period. Schemes will then have by the end of May to balance out their evidence and where they haven’t collected enough WEEE in any category, to buy evidence from a scheme who has over collected.

    Retailers of electrical equipment are required to either offer in-store takeback of WEEE on a one-for-one and like-for-like basis or join the Distributor Takeback Scheme that provided funds to Local Authorities for DCF development. There are separate requirements for producers who sell into the business market. They also have to join a scheme and submit data, but they have no market share responsibilities. However, they do have responsibility for the collection and treatment of business WEEE bearing their brand that was placed on the market after August 2005 when it reaches the end of its life.

    For producers, the requirements of the Regulations are relatively simple: they must register with a scheme, provide the scheme with weight of sales data and pay the bills. The Regulations are really only extremely complicated for Compliance Schemes and the enforcement Agencies.

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  • 3. What are the WEEE Regulations?

    The EU Directive on Waste Electrical and Electronic Equipment aims to deliver a more sustainable approach to managing electrical and electronic waste by increasing the volume of material recycled and reducing the amount sent to landfill. The UK was required to implement the WEEE Directive as Regulations by August 13 2004 although along with every other member state other than Greece, this date was missed. The UK Regulations finally came into force in January 2007 with full implementation on 1 July 2007.

    The Regulations place a responsibility on Producers to pay the costs of collection, treatment, recycling and recovery of WEEE. All producers regardless of size or market share are required to meet the requirements of the regulations. Producers are defined as those manufacturing, importing or selling under own label, electrical and electronic equipment.

    The Directive divides WEEE into 10 categories, each of which have different targets for recycling and recovery. These are listed in 4 below. The UK has introduced 3 further sub categories, also list below.

    All WEEE that is separately collected is required to be taken to an Approved Authorised Treatment Facility to be treated under regulatory guidelines. These treatment requirements are listed in 5 below.

    The Regulations also place a responsibility on retailers to ensure that an adequate network of collection facilities exists to allow consumers to dispose of their WEEE free of charge.

     

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  • 4. What’s required of producers?

    Producers are divided into two categories:

    1. those that supply electrical and electronic equipment (EEE) to households
    2. those that supply to businesses.

    Many producers will fall into both categories, but each has different responsibilities.

    For the purposes of registration, producers are companies registered with Companies House or acting as sole traders or partnerships. There is no provision for Group registrations in these Regulations.

    Regardless of the approach that may be adopted, producers who supply EEE to household consumers will be required to:

    • Register with an approved Compliance Scheme
    • In 2007, provide 2006 sales data (i.e. the weight of equipment sold for each of the 13 categories)
    • Finance the collection, treatment and recycling/recovery of WEEE from Designated Collection Facilities (DCF)
    • Provide evidence of compliance
    • Producers will have the option of performing these responsibilities themselves or outsourcing to a compliance scheme such as Transform.

    For those supplying to business users, the requirements have yet to be debated fully and it is unclear as to exactly the Directive requirements will be transposed. But it is likely that B2B producers will have to:

    • Register, providing annual sales data as above, but specifically for EEE supplied to businesses. Where a producer supplies to both the household and business sector, they will be required to make ‘reasonable estimates’ of the split.
    • For equipment supplied to businesses after August 13th, 2005, producers must finance the costs of collection, treatment, recovery and disposal unless alternative arrangements have been made with the user.
    • For equipment supplied until August 13thth 2005, producers are only responsible for financing the costs of collection, treatment, recovery and disposal of equipment on a like-for-like basis, interpreted in the draft legislation as "new equivalent products or new products fulfilling the same function"

    Producers who place B2B and B2C products onto the market have a choice of registering each obligation with a separate scheme or with a single scheme. However, a producer cannot split his registration under either B2B or B2C between two schemes.

    In addition, producers will be required to:

    • Ensure correct markings and labelling are on products placed on the market (see 6. below)
    • Make available information on components that can be reused and recycled
    • Ensure that products placed on the European market from 1 July 2006 conform with the RoHS requirements

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  • 5. What’s required of retailers?

    Retailers are referred to as Distributors through the Regulations. Every retailer selling electrical goods, no matter how small a part of their business, will be required to register and contribute to a central fund or offer free in-store take back from implementation date on a 'like for like' basis. Unlike the Packaging Waste Regulations, Charities are NOT exempt.

    The government requires retailers to ensure that there is an 'adequate network' of facilities that allow consumers to be able to dispose of their WEEE free of charge. The government decided to tender out the running of a Distributor Takeback Scheme that would have responsibility for delivering this adequate network.

    This was contracted out to Valpak for a three year period that ends on 31 Dec 2009. This took responsibility for raising the necessary funds from EEE retailers – approximately £10m – and using them to fund the enhancement of the Civic Amenity site network to improve their WEEE separation capabilities

    Retailers are given the option of either joining the DTS for a fee or offering in-store take back for all categories of WEEE sold in their shop. If they choose this option, they are entitled to free disposal if they take any items brought back by consumers to a collection point determined by a Producer Compliance Scheme.

    WEEE received by stores will be counted as their own waste and will therefore not lead to sites requiring a special licence.

    Retailers will also have to provide information to consumers on how to dispose of electrical waste, either through the store if they operate take back or through the compliance scheme.

    Distance sellers (e.g. internet distributors) face the same responsibilities as shop-based retailers.

    Retailer responsibilities are policed by the Vehicle Certification Agency (VCA) who provide useful information on in-store literature and notices.

     

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  • 6. What are the implications for local authorities?

    Local Authorities currently collect the majority of WEEE through the Civic Amenity site infrastructure and it is the government’s expectation that this should form the backbone of the ‘adequate infrastructure’ required under the Directive. However, to satisfy the expected requirement for WEEE to be separately grouped for ease of collection and treatment, many sites will need to be upgraded with improved facilities. The government has stated that there should be no additional financial burden on LAs through the WEEE Regulations and it is therefore proposed that the Retailer fund will pay a set amount (expected to be around £8k/DCF) to each participating Local Authority. However, LAs will still have to consider the implications on existing contracts with site operators, lost values for WEEE that might currently be collected for recycling in mixed metals skips and the effects of WEEE collection contractors on their site operations.

    One of the issues for LAs is that collection facilities will need to be permitted for Hazardous Waste and under the new WEEE Permitting Regulations.

    • Any site that carries out ‘treatment’ of WEEE (dismantling, shredding etc) will have to be permitted
    • Sites may store less than 60m3 of WEEE for up to 3 months under an exemption so long as the WEEE is being treated elsewhere

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  • 7. What products are covered by the WEEE Regulations?

    The directive divides WEEE into 10 categories, each with its own recycling and recovery targets. The Government have sub-divided some of the categories to produce a further 3. The scope of what is classified as WEEE has yet to be fully defined, but the government wishes the interpretation to be pragmatic and only apply the WEEE Regulations to items who’s primary purpose requires the electrical function.

    The Regulations will specifically exclude certain items including:

    • Products intended solely for military purpose
    • Filament light bulbs
    • Household luminaries
    • Large scale fixed industrial tools
    • Implanted medical devices

    The 10 EU categories are as follows:

    • Category 1 – Large household appliances (fridges, cookers, microwaves, washing machines etc)
    • Category 2 – Small household appliances (vacuum cleaners, clocks, toasters etc)
    • Category 3 – IT and Telecommunications equipment (PCs, mainframes, printers, copiers, phones etc)
    • Category 4 – Consumer equipment (radios, hifi, musical instruments, videos, camcorders etc)
    • Category 5 – Lighting equipment (Fluorescent tubes and holders, sodium lamps etc)
    • Category 6 – Electrical and electronic tools (drills, sewing machines, electric lawnmowers etc)
    • Category 7 – Toys, leisure and sports equipment (electric trains, games consoles, running machines etc)
    • Category 8 – Medical devices (Analysers, dialysis, medical freezers etc)
    • Category 9 – Monitoring and control equipment (smoke detectors, thermostats, scales etc)
    • Category 10 – Automatic dispensers (hot drinks machines, sweet and chocolate bar dispensers, cash machines etc)

    The three further categories are:

    • Category 1a - Display equipment (Computer screens and Televisions)
    • Category 3/4a - Cooling appliances containing refrigerants
    • Category 5a - Gas discharge lamps

    The targets for the categories are as follows:

    • Categories 1 and 10 – 80% recovery and 75% recycling (recovery can include waste to energy)
    • Categories 3 and 4 – 75% recovery and 65% recycling
    • Categories 2,5,6,7 and 9 – 70% recovery and 50% recycling
    • Gas discharge lamps – 80% recycling

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  • 8. What ‘Product Markings’ are required?

    All EEE placed onto the market (see definition at the end) from 2 January 2007 must be marked with the appropriate recycling symbol of a crossed out wheelie bin of at least 5mm height and either a black rectangle or a date stamp showing the date of manufacture. If the item is too small, then the markings must be placed on the operating instructions, warranty and packaging.

    Product Markings

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  • 9. What is meant by ‘treatment’?

    All separately collected items of WEEE must be taken to an Authorised Treatment Facility (ATF) to have certain items removed prior to processing to meet the recycling and recovery targets. The environmental agencies have now produced treatment standards suggesting that certain items can be removed mechanically - circuit boards and batteries in particular – as long as they are recognisable and do not contaminate other items. This would indicate that for many items – cookers, washing machines and computers, for instance – shredding through a slow speed shredder will still be an option. Clearly, this will have a big impact on cost.

    The items requiring removal are as follows:

    • All fluids
    • Polychlorinated biphenyls containing capacitors
    • Mercury containing components
    • Batteries
    • Printed circuit boards of mobile phones and other items if above 10 sq cms
    • Toner cartridges
    • Plastic containing brominated flame retardants
    • Cathode ray tubes
    • CFCs, HCFCs, HFCs or HCs
    • Gas discharge lamps
    • LCDs greater that 100 sq cms surface area
    • External cables

    All ATFs will have to be permitted under the new WEEE Permitting Regulations but as discussed in 4. above, delays on these could lead to the need for transitional arrangements.

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  • 10. What is meant by like-for-like products?

    The definition of like-for-like products refers to equipment that performs the same function, e.g. a CRT TV when buying a LCD TV or a cassette player when buying an MP3 player.

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  • 11. What is meant by ‘separately collected’ items?

    The WEEE Directive only requires items that are ‘separately collected’ to be dealt with as WEEE and taken to an ATF. Therefore, items placed in bins of mixed waste – such as the household wheelie bin – will not have to be dealt with as WEEE. There is some confusion as to how this may apply to business waste as in theory, it could mean that businesses could place electrical and electronic waste in their general waste bin and therefore not have to dispose of it through treatment although we understand that officials are trying to find a way to prevent this happening. However, the government hopes that businesses will take a more environmental approach and given that many WEEE items will be classed as hazardous waste, will deal with their WEEE appropriately and avoid placing a monitor containing a CRT in a skip of general waste, for instance. The Regulations do not mention ‘separately collected’ but it is expected that there will be reference in the Guidance.

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  • 12. What is the annual timetable?

    Scheme

    & AATF/AE data

    Agency data

    		Date

    Registration

    and compliance
        1 Jan Compliance period starts
    Q4 submitted  by schemes   31 Jan  
      First cut of national data back to schemes for previous year 1 Apr  
    Q1 data submitted by schemes Final market share to schemes 30 Apr  
      Q1 national data back to schemes 31 May Schemes must submitted DoC for previous compliance period
    Q2 data submitted by schemes   31 Jul  
      Q2 national data back to schemes 31 Aug  
        15 Oct Producers must register with schemes
    Q3 data submitted by schemes   31 Oct Schemes register members
      Q2 national data back to schemes 31 Nov  
        31 Dec Compliance period ends

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  • 13. What’s the role for Compliance Schemes?

    All producers have to register through an approved Producer Compliance Scheme. They can register themselves as a Scheme, but must still go through the full approval process – and pay the £12,174 fee that each scheme will have to pay for 3 years approval. Compliance schemes will be legally liable for achieving their member’s obligations and must have approval through the Secretary of State. The Regulations apply strict requirements for approval, including an operational plan, financial security, operation by a fit and proper person etc. There are now over 40 schemes, some of whom are solely for B2B producers.

    B2C schemes have a market share obligation that comes from the data supplied by them to the Environment Agency for EEE placed onto the market by members. The scheme will have to estimate what tonnage of WEEE in each of those categories is likely to arise in the UK through the compliance period and then apply its market share to estimate the amount of evidence it is likely to have to collect. If, therefore, it’s members place 5,000 tonnes of Category 1 (non cooling devices) on the market in 2008 and the total data submitted shows that 500,000 tonnes of such products were placed on the market in that period, then the scheme will have a 1% market share. If, during the compliance period, 200,000 tonnes of WEEE in that category was collected across the UK, then the scheme would have to have evidence in relation to 2,000 tonnes of that 200,000 tonnes. The quarterly data submissions and data provided back by the Agencies will give schemes a quarterly overview of their position. However, both the market share and total to which it is applied are moving feasts which only finally determined by data published by the EA three months after the end of a compliance period. Schemes therefore have to charge their members to ensure that they fully recover any costs incurred and are likely to mitigate the risks by overcharging in advance and providing a rebate on final reconciliation.

    For producers, Compliance Schemes will:

    • Take legal responsibility for complying with the Regulations
    • Help them to understand their data requirements
    • Submit their data to the appropriate environmental Agency
    • Manage collection, treatment and recovery related to the market share of the scheme for each of the 13 categories
    • Demonstrate that recycling and recovery targets have been met for each of the 13 categories

    Transform operates a producer Compliance Scheme for both B2C and B2B producers.

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  • 14. What responsibilities have been placed on business users?

    All separately collected electrical and electronic waste must be treated and meet recycling and recovery targets, unless reused. In theory, for EEE placed on the market prior to August 2005, businesses can get suppliers of new equipment to take away old equipment on a one-for-one basis free of charge or make alternative financial arrangements with the supplier. For EEE marked with the crossed out wheely bin, the last user has, in theory, the right to get the producer whose brand is on the product to come and collect it free of charge. However, the Regulations allow producers to contract out of that liability when they sell the product and anyway, it is difficult to see how either of these requirements will work in practice given the distance between the end user and the producer in the supply chain. This is a subject for further detailed discussion between DTI and industry.

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  • 15. Is there a visible fee allowed in the Regulations?

    Some of the UK’s main EEE producers have been vociferously lobbying the government for the inclusion of a visible fee in the Regulations. This is where a receipt at point of sale shows a separate cost to the consumer for the recycling of the type of product bought. However, the Regulations have only given producers the power to show a visible fee when they sell the product to a ‘purchaser’ which would normally be a retailer or wholesaler. It is therefore unlikely that the UK will see a separate charge on the till receipt unless a manufacturer supplies direct to consumers.

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  • 16. What is a Designated Collection Facility (DCF)?

    It is expected that producers will only have responsibility for the cost of collecting and treating WEEE from DCFs. The majority of DCFs will be Civic Amenity sites operated by councils, but other DCFs could be set up including retail distribution centres that WEEE is brought back to, transfer stations and community re-use facilities.

    DCFs will have to be approved by the DTI. This is likely to require adherence to a yet-to-be defined Code of Practice and agreement by a DCF to work with Compliance Schemes. The Code is likely to require DCFs to have the ability to store WEEE in 5 groupings of categories:

    1. Categories 1 and 10 – Large household and dispensing equipment (other than fridges and freezers)
    2. Fridges and freezers
    3. Categories 3 and 4 – IT/telecoms and consumer equipment
    4. Categories 2,6,7 and 9 – small household, tools, toys and leisure
    5. Category 5 – Lighting

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  • 17. What’s the role of the regulatory agencies?

    The regulatory agencies (Environment Agency in England and Wales, SEPA in Scotland and EHS in Northern Ireland) will have responsibility for policing all aspects of the regulations. This will include:

    • Registering producers
    • Ensuring producers are registered and discharging their legal obligations
    • Permitting of authorised treatment facilities and approving them to certain standards of operation relating to their ability to meet recycling and recovery targets
    • Permitting of collection facilities and approving them to the required standards, including ensuring they are not exporting waste illegally
    • Ensuring retailers have either joined a scheme or are offering sufficient take back and providing the required information (although it is likely that this will only be done if reported by the Retail Compliance Scheme)
    • Monitoring producers and schemes to ensure that they are registered, provide accurate information, satisfy the information requirements, apply adequate markings and meet targets
    • Policing the export of waste
    • Ensuring businesses dispose of waste in an acceptable manner and are responsible to the national clearing house
    • Providing advice on scope and other issues

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  • 18. How will the evidence system work?

    For household WEEE, the Regulations require schemes to demonstrate that they have complied with their obligations by ensuring that they have sufficient evidence of collection, treatment and recycling in relation to their market share in each category. Evidence of the weight of WEEE collected, treated and recycled will only be able to be produced by Approved Authorised Treatment Facilities (AATFs) who will have to also produce evidence where WEEE has been removed for re-use (as this cannot be used as evidence of recycling). The AATF has to be able to demonstrate to the enforcement authorities as part of its accreditation that it is able to show an audit trail to reprocessors for the by products of the Treatment process in order to show that the recycling targets have been met. AATFs will issue WEEE Recovery Notes through a government contracted Settlement Centre. This will have no commercial function, but only evidence placed on the SC will be valid. WEEE will also be able to be exported under certain circumstances, but ‘evidence’ for compliance purposes will only be able to be supplied by accredited Exporters.

    Given the imbalance that each scheme will have between the amount of WEEE it has collected and its precise obligation, there will always be a need for ‘trading’ of evidence. The calculation carried out by the EA two months after the end of a Compliance Period will create a specific demand which should exactly match the available supply. Schemes will then be able to trade evidence that can be exchanged between schemes through the Settlement Centre in order to balance up. By the end of May following a Compliance Period, schemes will have to be able to demonstrate that they have exactly the right amount of evidence for each category.

     

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  • 19. What about Re-use?

    The Directive specifically encourages re-use by requiring all WEEE to be collected in a way that facilitates re-use. It is likely that the majority of WEEE will be un-economic to re-use, but schemes will have to demonstrate in their Operational Plans how they intend to work with re-use groups and ensure that re-use is maximised.

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  • 20. What are the likely costs?

    Costs will be dependant on many factors that are still to be resolved including the data requirements, registration fees, treatment standards, permitting requirements, quantity of producer registrants etc etc. It must also be recognised that under the new Hazardous Waste Regulations that came into force in mid July 2005, many items of WEEE eg fridges, TVs, fluorescent tubes are classed as Hazardous and will therefore incur additional cost burdens.

    The Regulations have introduced a tiered annual Agency fee structure that has to be paid by each scheme for each of its members regardless of whether they are B2B or B2C.

    < vat threshold - £30
    vat - £1m turnover - £220
    > £1m turnover - £445

    Each scheme will also have its own cost structure to recover the costs of operating and of collecting, treating and recycling WEEE from its members.

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  • 21. What should I do now?

    • There are now over 40 approved Producer Compliance Schemes although some are ‘closed schemes’ for a single member. These are listed on the EA website.
    • You should consider which scheme is best likely to suit your requirements. For some, the registration fee might be the critical factor, but others might wish to consider a scheme that has more of an operational or compliance background and not wish to risk registering purely on the up front costs.

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  • 22. Where can you find more information?

    Transform – www.transform-uk.net or 01494 556565
    BERR
    EA
    SEPA
    NIEA
    VCA

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  • 23. Glossary of Acronyms you will come across in WEEE

    • AATF – Approved Authorised Treatment Facility
    • CA Sites – Civic Amenity sites (council tip)
    • CRT – Cathode Ray Tube
    • CS – Compliance Scheme
    • DCF – Designated Collection Facility
    • DEFRA – Department of the Environment, Food and Rural Affairs
    • DTI – Department of Trade and Industry
    • DTS – Distributor Takeback Scheme
    • EA – Environment Agency
    • EEE – Electrical and Electronic Equipment
    • EHS – Environment and Heritage Service (Northern Ireland environmental agency)
    • ICER – Industry Council for Electrical Equipment Recycling
    • LHA – Large Household Appliances
    • RoHS – Restriction of Hazardous Substances
    • RIA – Regulatory Impact Assessment
    • SEPA – Scottish Environmental Protection Agency
    • SEWPF – Strategic Electronic Waste Policy Forum
    • SHA – Small Household Appliances
    • TAC – Technical Adaptation Committee (EU)
    • WEEE – Waste Electrical and Electronic Equipment

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  • 24. Some useful definitions

    • ‘Placed onto the market’ – manufactured in the UK and out of the factory gate or imported through customs
    • ‘Producer’ – importer, manufacturer in the UK or own brand supplier
    • ‘B2B – Business to Business (EEE or WEEE) products
    • ‘B2C’ – Business to Consumer (EEE or WEEE) products
    • ‘EEE’ – electrical or electronic equipment placed on the market
    • ‘Separately collected’ – WEEE that is put out for collection separately to other waste or recyclables
    • ‘Re-use’ – Repair or refurbishment for further use
    • ‘WEEE’ – electrical and electronic equipment that conforms to the scoping criteria and which is discarded by its final user
    • ‘Supplier’ – an organisation that supplies electrical and electronic equipment to the end user. This can be – but is not necessarily – the producer.
    • ‘Retailer’ – any organisation that sells WEEE to domestic consumers

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  • 25. Some examples of grey areas and Agency positions

    Item In/out Category Comment
    Household lighting out   All household lighting (other than fluorescent tubes and sodium bulbs) exempt including Christmas tree lights.
    Stand alone fixed industrial tools (lathes etc) in 6  
    Fairground ride out   Large scale item made up of several pieces of equipment
    Battery chargers in   Should be in same category as item they are used for
    Car park barriers and parking meters in 9  
    Disposable cameras In 4 Disposable cameras that are recycled should be declared as non-household EEE as they will end up as commercial waste
    Electric showers, immersion heaters etc in 1 Even though they are installed in a house
    Extension cables, adaptors, leads in 2 If supplied with specific equipment, they should be included in equipment weight and in equipment category
    Fish tanks with built in lighting, pumps etc in 7 The whole weight of the item should be included.
    Furniture with electric components – electric recliners etc out   The primary function does not need electricity although massage chairs are in – Cat 1.
    Portable in car entertainment – eg sat nav, DVD players in 4 A replacement radio/CD player that is wired in and would remain with the vehicle is out.
    Memory cards and sticks, SIM cards, in 3  
    RFID including anti theft, pet chips etc in 9  
    Power supply units in Same as unit they are used for  
    Roller screen, electric garage door in 2  
    Solar panels Out    
    Spa baths, hot tubs In 1  
    Stairlifts Out   Not in any of the categories
    Sunbeds in 2 and 5 Beds should be in 2, lamps should be in 5
    Torches In 2  
    Utility meters in 9  
    Wind up torches, radios etc in   Category depends on product

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