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Sourcing >> WEEE
directive: What EU electronics importers must know

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WEEE directive: What EU electronics importers must know

Posted: May 27, 2015

by Fredrik Gronkvist

Unlike RoHS, which restricts usage of heavy metals in
electronics, the WEEE (Waste Electrical and Electronic Equipment) directive has
several elements, each having an on electronics importers in the EU. Among there
are recycling contribution schemes, dismantling design requirements, and
labelling requirements. We will get back to those in a bit, but first you might
want to know which product categories are within the scope of regulation.

CATEGORY

EXAMPLES

Large household appliances

Refrigerators, Freezers, Washing Machines,
Electric Stoves, Microwaves, Heating Appliances

Small household appliances

Vacuum cleaners, toasters, irons, sewing machines,
watches and clocks

IT & Telecom

Printers, Laptop Computers, Phones, Tablet
Computers, Fax Machines

Consumer equipment

Radios, TV sets, Video Cameras and recorders,
Audio Equipment, Musical Instruments, Other Displays

Lighting equipment

Lamps, Bulb Lights

Electronic tools

Saws, Welding Machinery, Drills, Cutting
Machinery, Gardening Tools

Toys, leisure and sports

Video game consoles and accessories, Electric
sports equipment, Electric toys

Medical devices

Laboratory equipment, Radiotherapy
equipment

As hinted by the table above, if your business is importing electronics
within the EU, the WEEE directive is having an impact on your business. However,
note that the table above is not listing all categories, or products, within its
scope of regulations. For a more comprehensive list, click here.

Eco-design and product dismantling requirements

The design for dismantling (also known as design for recycling, or design
for disassembly) includes the practices to optimize the way how a product will
be treated at end of life, and to optimize the separation of components and
materials for their recovery (repair, recycling, energy recovery). The design
for dismantling applies equally to a product to be disassembled as for products
intended to undergo a grinding step.

Considerations are particularly related to choice and combination of
different materials that compose a product but also to the assembly and
mechanical connections between components and subassemblies of the product. Source

The WEEE directive requires products to be designed in a way that simplifies
the dismantling, for either recycling or further usage. As WEEE covers such a
large number of products, there are, at least as of today, no technical
requirements applicable to each product. As such, it’s up to the "producer"
(i.e., the importing company, when the supplier is located outside of the EU) to
ensure that the product is designed in compliance. For example, this may include
the following:

Removable batteries

Easy separation of electrical components

Easy separation of different materials (e.g. metal alloys and
plastic)

For startups and small businesses, lacking the technical capability, or
budget, to develop OEM products, or at least modify an existing factory design, this poses a major challenge.
My best advice for this group of buyers is to make a compliance assessment based
on factory samples. However, most Chinese electronics manufacturers are, for natural
reasons, not concerned with ensuring said design compliance. As always, Western
buyers must strictly limit their supplier selection to those with an existing
compliance track record.

WEEE labelling requirements

Take a good look at your phone or laptop charger. The WEEE symbol, as seen on
the right, indicates separate collection and recycling. The WEEE mark is
mandatory for most electronics, imported and sold within the EU.

The WEEE mark must be clearly visible on the product itself, and its
packaging, unless this is deemed to be impractical. Also note that the WEEE mark
is not a replacement for a CE mark, which indicates compliance with all other,
applicable, EN directives.

When buying from China, never leave the product labelling in the hands of the
manufacturers. Provide all graphics files, including labels, directly to the
supplier, rather than making the assumption that they'll 'get it right'. After
all, your business is taking the heat if the products turn out to be improperly labelled

WEEE registrations and yearly contributions

In addition to dismantling design and labelling requirements, the WEEE
directive also sets yearly ‘recycling contribution’ requirements, for importers
and distributors. In practice, this means that your company must pay its fair
share to finance the recycling network, on a yearly basis. These recycling fees
are based on yearly sales volume, usually counted in tons.

There are certain limitations though. For example, in the United Kingdom, the
yearly contribution only applies to companies with yearly sales volumes
equivalent of at least 5 tonnes:
A small producer must join a PCS
(producer compliance scheme) within 28 days of placing more than 5 tonnes of EEE
on the market in any compliance period.

What I must also mention at this point, is that the WEEE Directive is
implemented individually by each EU member state, according to its own ‘national
producer compliance scheme’. As such, the implementation may differ, to a
varying degree, between different EU member states.

Further reading

UK Government Guidance Notes: WEEE Regulations
2013

Kingfisher Sourcing: Basic Requirements for the WEEE
Directive

Eco
Design Guide of WEEE Compliance Schemes

Fredrik Grönkvist is the co-founder of ScandinAsian Enterprise in
Shanghai. Since 2010, he and his team have helped hundreds of companies
worldwide, primarily in the EU and US, to develop and manufacture products in
China. He is also the main contributor on http://www.chinaimportal.com/,
a leading knowledge base for small- to medium-sized enterprises importing from
Asia. For further questions, you can contact him on www.chinaimportal.com/contact-us/

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