The WEEEdirective. ( echoes of part P ?)

[Derek Geldard]

On 2 January 2007 the Waste Electrical and Electronic Equipment Regulations 2006 come into force. The burden it puts on small businesses is draconian. Businesses of all sizes have only until until

15 March 2,007 to join an approved Producer Compliance Scheme. Total cost of the whole compliance package £1 - 2k in annual membership charges before a single printed circuit board has been recycled.

There is no minimum company size; the regulations apply to all producers whatever their turnover, market share or number of employees.

For us the cost of doing this is out of proportion to the profit generated by our equipment sales so we are considering withdrawing our product from the market. However we will still have a reasonable business in supplying spare parts and service for machines sold over the last 20 years. Unfortunately the information on government web sites appears to have been written by the Bosnian Serbs, and the commercial sites contradict each other, are sometimes out and out wrong and can not be regarded as impartial.

It's a criminal offence not to register before 15th of March, so ...

Please, does anybody happen to know:

Is repairing a 12 year old machine using new spare parts "Putting a product onto the market", thus requiring registration ?

Is selling new spare parts for a customer to repair his 12 year old machine "Putting a product onto the market".

DG

[Andy Hall]

I've looked at this whole area at many times in the past - originally in connection with the EMC Directive.

Placing a product on the market is one or more of:

- Manufacturing within the EU and selling it directly or through a channel

- Importing it and selling it as a subsidiary of a company established outside the EU

- If you are a reseller, distibutor,... importing it from a manufacturer outside the EU and selling it.

Neither of the scenarios you describe constitute placing the product onto the market - i.e. you can supply spares and repair.

In the context of the rest of it, to be honest, I would take a commercial view. The EMC Directive was bad enough. WEEE aspires to be a shambles.

I think that there are three courses of action

- Take product off of market

- Look at registration and the commercial implications.

- Ignore the whole thing. Keep going as before. If you are a small business, it is very unlikely that anything will come your way any time soon. Look at the financial and other penalties. For example - worst case with EMC is £5000 and 6 months in the pokey. Realistically £5K is absolute worst case for this. I haven't looked at WEEE in this regard, but for sure is you are a small business there are much bigger fish for the jobsworths to fry.

If the product isn't that lucrative then certainly take it off the market, but I wouldn't feel bullied about that.

[Clive George]

If going down this route, presumably it would be sensible to do some of the appropriate bits - eg the little bin sticker, and maybe ensuring the customers know to send it back to you at the end of its life/arranging for suitable disposal.

cheers, clive

[Jonathan Schneider]

No. Do tell.

Jon

[John Rumm]

From what I can see the costs will depend on if you are classed as a manufacturer / importer or simply a distributor. Costs for the former are in the range you quote, however for the latter are likely to be less (although are as yet undefined).

And the "tax" is based on the weight fo goods sold, not their value.

Another few years of this and the country will be full to busting with criminals... and most of them won't even realise it.

I probably depends on if the parts are classed as "WEEE"... so a replacement gearbox no; psu yes.

I don't know, although it seems sales to end users seem to attract less paperwork complexity than sales to business.

[Derek Geldard]

The ones I heard of were small time PC system builders on High Streets who fitted extra peripherals without going through re-testing, or fitted a different model PSU F. I.

A system buit from CE marked sub-assemblies ! = a CE compliant system.

DG

[Frank Erskine]

It doesn't really matter. All the prisons are full, so this guvmint will just polygraph everybody, then lose all the records...

[Andy Wade]

There are many grey areas in WEEE, but that's not one of them. Obligations apply only to complete equipment and not to components or spare parts of any kind. (AIUI, IANAL, etc.)

[Huge]

Of course they can.

[Andy Hall]

Precisely. The whole thing is a nightmare even for manufacturers.

RF emission and susceptability changes also according to what is connected and the cables so one really needs to test a complete system.

In practice, most manufacturers test a few typical configurations as it isn't realistic to test all combinations.

[manatbandq]

You only get the pokey if you ignore instructions to stop or obstruct=20 the inspectors.

MBQ

[Roger Mills]

And even then, you probably have to join the waiting list!

[Derek Geldard]

It so happens that our machines are very heavy 425kg but contain relatively little electical / electronic content, say 25 Kg. Whilst we don't know what the per tonne charge will be it looks like we would be hit with a very heavy cost. Afaik you can't break out the electronics bit yourself and dispose of the rest as scrap metal, the PCS has to collect and transport the waste in a licensed vehicle. I can't see how this will work out as it has cost us in the past £1,100 to get a machine *into* a customer's dept. (Placed by quality assured installation contractors). 8-(

It also appears that we are obliged to remove and dispose of a redundant competitors machine if we sell a new one of our own.

That would put the tin hat on it.

This site has more details than most :

's also an additional charge of £200 + quid that goes to the environment agency.

No doubt the £6.00/tonne refers to the most easy to process homogenous waste in full truckloads very close to the depot.

All in all not a very encouraging prospect.

Just as well we sold no "WEEE" in 2006 ...

and I took my pension as of last Friday. :-))

DG

[tim.....]

Do you mean the little 'not' bin logo.

Does anyone really think that the average punter is going to take any notice of this and 'not' put a broken remote contol in the bin?

tim

[Clive George]

That's not why I suggested doing it - it's one of the requirements, and I was suggesting that if one had taken care to do what one could, it would stand in your favour should people catch you.

cheers, clive

[tim.....]

Yes, I know.

I was just asking the question generally.

Does anyone really think that by putting a little symbol on a 'throw away' electrical item that I won't throw it away?

It's not like they will come and collect it from me and AIUI, (unlike in other EU countries) I don't even get the option to take it back to an electrical shop but have to take it to some 'special' place, which I have little doubt will be the council tip.

tim

[Chris Hodges]

And won't be available for x months after the directive comes into force no doubt.

[Chris Hodges]

If all of a representative range passes easily, it's low (but not 0) risk to self certify similar products.

[Derek Geldard]

And even as to how the cables are laid out.

No PC I've seen has had any kind of standard, repeatable, cable form. It's just a case of shovel it all in the box and try and get the cover on, put your foot behind it if necessary.

Our people in Holland tested the most complete configurations and then offered cut down options. Rather than testing the base model and offering enhanced functionality as options that had not been tested.

DG

[John Rumm]

Last I read, disposing of WEEE in a wheelie bin *is* actually considered acceptable for a consumer (although not a business).