WEEE RECYCLING COMPLIANCE SERVICES

¨WEEE¨ stands for ¨waste electric and electronic equipment¨ and refers to end of life electric or electronic equipment. WEEE can range from old or broken mobile phones, washing machines or laptops (these would be considered household WEEE) to servers, automatic dispensers or radiotherapy equipment (these would be considered professional WEEE). In the United States and several other countries it is known as e-waste (electronic waste).

The EU Directive 2012/19/EU (WEEE Directive) aims to prevent or reduce the negative environmental effects resulting from the generation and management of WEEE. Its key purpose is to contribute to the prevention of WEEE and, in addition, the promotion of the re-use and recycling of such wastes. 

All 27 EU Member States have transposed the EU WEEE Directive into national laws. There are many similarities among those national laws but also several significant differences. Companies selling into the EU may need to comply with those national laws in all Member States where they sell.

You can check whether your products fall under the scope of the WEEE Directive using this tool from the European Commission. Most electric or electronic products are in scope but there are a few exemptions (military equipment, large-scale stationary industrial tools and some others).

If your products are in scope you may have obligations in the EU countries where you sell your products. This will depend on several factors like whether you sell from local or foreign legal entities, directly to end users or through resellers or the types of products you sell (household vs. professional products).

That will depend on how you sell your products. In general, if you sell directly to end users you will be obligated to register as a producer. If you sell through resellers based in the EU you may not have to register as a producer (in that case, your resellers would need to complete the registration). We can help you identify your obligations (taking into account your sales arrangements) and find out whether your resellers are compliant with WEEE regulations.

There are many non European companies who sell their products through resellers based in the EU. If those resellers are importing the products into the EU then they will be responsible to register as WEEE producers for those products. However, quite often those resellers (especially those based in Germany) ask manufacturers to do that for them. Some countries (like Germany, Italy and Spain) do allow foreign manufacturers to register on behalf of local resellers whereas others (like the Netherlands and Belgium) don’t allow it. There are also EU countries (like Portugal and Sweden) who only allow companies based in other EU countries to register on behalf of local resellers.

Your company will need to register in each EU country where it has obligations. The following list shows all European WEEE Registers by country. There is no such thing as a Pan-European WEEE registration (see explanation provided by the European network of WEEE Registers).

Local entities are allowed to register directly with the WEEE National Register whereas foreign entities must appoint an Authorized Representative in each country where they need to register as producers.

In most countries (especially if you sell household products) you will also need to join a collective recycling organization. Those organizations provide several services.

Yes. Apart from officially registering as a WEEE producer, obligated companies are required to: report on a regular basis the quantities and weights of electronic products placed on the market,  provide information to end users regarding what to do with their end of life products, organize and finance the take-back and recycling of WEEE (directly or through a collective recycling organization) and submit reports to Authorities regarding their take-back and recycling activities.

There could be severe consequences for non-compliance. From significant fines imposed by National Authorities to products being banned from EU countries. Many resellers also request manufacturers to prove they are compliant with WEEE regulations in order to take on their products.

Extended Producer Responsibility is an environmental protection strategy within the field of waste management that makes the manufacturer of the product responsible for the entire life cycle of the product and especially for the take-back, recycling and final disposal.

This policy approach has been adopted into legislation in many countries. Some of the most known examples of this strategy are the EU WEEE, Battery and Packaging Directives. The EPR approach places the financial responsibility for product end of life management onto producers.

If you have obligations as a WEEE producer and your products contain batteries then it’s very likely you will also have obligations as a battery producer in the EU countries where you sell your products.

The new Battery Regulation (EU) 2023/1542 and the associated national laws issued by the 27 EU Member States intend to contribute to the protection and preservation of the environment by minimizing the negative impact of waste batteries and accumulators. 

Requirements to comply with EU Battery laws are similar to those for WEEE. They include registering as a producer with National Registers, reporting put on market and recycling quantities, providing information to end users and financing and organizing the take-back and recycling of waste batteries and accumulators.

If you have obligations as a WEEE producer you may also have obligations as a packaging producer in the EU countries where you sell. The Packaging Directive (94/62/EC) is older than the WEEE Directive and it does not explicitly mention obligations for distance sellers. However, several EU countries do oblige foreign entities selling directly to end users to comply with their national packaging laws. All EU countries oblige legal entities established in the same country where they sell products into to comply with packaging regulations.

The EU adopted the Circular Economy Action Plan (CEAP) in March 2020. It’s one of the building blocks of the European Green Deal and it will impact how products are designed, promote circular economy processes, encourage sustainable consumption, and aim to ensure that waste is prevented and the resources used are kept in the EU economy for as long as possible.

The following implementation plan includes several actions related to the CEAP scheduled for the period 2020-22. Changes on Eco-design regulations and new legislation on the repairability of products are two examples of changes that will impact WEEE producers.