WEEE and RoHS From Here to Compliance

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WEEE and RoHS From Here to Compliance
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Current status

• Final Government consultation closed on 29th
  October 2004
• Draft regulations and guidance available at the
  DTI website
• Executive summary and assessment of previous
  responses also available
• Recent announcement of timescales.
• UK regulations expected Summer 2005. Target date
  for commencement of WEEE obligations is January
  2006.
• Registration Summer 2005 short consultation
  on level of Agencies fees.
• There are ongoing discussions on many issues

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Producer Registration

• Will you be classed as a producer?
• Registration will commence this summer
• It will be a requirement of placing products on
  the market
• Register with the Environment Agency
• Data on product types, sales numbers, weights and
  retail/non-household sales split will be needed
• Will incur a fee which has yet to be set will
  be based on size and turnover of company
• Further consultation on this shortly.

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Product Marking

• WEEE marking is due to commence on 13th August
  2005.
• Products will have to be marked with brand (or
  identifier), date of manufacture (or a mark to
  signify that it was placed on the market after
  this date) and
• Standard EN 50419 now exists however it is
  already under review
• Also information for users, consumers and
  recyclers and on presence of hazardous materials
  and other issues this can be on CD, telephone
  helpline or website

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RoHS Compliance

• Deadline is 1st July 2006 but in real terms it
  may be much sooner due to supply chain issues
• Where might RoHS materials be used in your
  products at present?
• Start issuing materials declaration forms now and
  talk to your suppliers.
• Try and get these discussions completed by Jan
  2006 at the latest
• Start to consider the development of a testing
  regime to demonstrate due diligence
• A self certification approach is proposed are you
  happy to sign these declarations?

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National Clearing House

• WEEE will be administered by a National Clearing
  House (NCH)
• Initially it will be run by the DTI and the
  Environment Agencies.
• Waste will be collected on demand and delivered
  to the relevant parties for treatment, recovery,
  recycling or refurbishment
• The clearing house would be funded by producers
  (possibly though a registration fee) and would
  operate on a not for profit basis.
• It will not cover business to business WEEE.

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Proposed Clearing House (contd.)

• The Environment Agencies will register producers
  and DTI will establish an allocation of WEEE to
  producers.
• Each WEEE collection site would be allocated to a
  particular producer or compliance scheme on a
  three year basis
• Allocation will mix physical allocation to larger
  producers and compliance schemes and a settlement
  mechanism enabling financial compliance by
  producers with smaller market share obligations.
• Data on recycling and recovery of different
  categories may be produced by using protocols
  which set down the average amount of separately
  collected WEEE in each category.
• Government will work to further to resolve
  methodology for the allocation of WEEE.

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Business WEEE

• Business WEEE will be funded by either the
  producer or the customer
• If products that were sold before 13 August 2005
  are exchanged on a like for like basis then the
  producer will have to cover costs of recovery and
  recycling when dealing with historical waste
• If equipment is not exchanged then the end user
  may be responsible
• Businesses can use contractual agreements to
  override the defaults in the legislation
• Government convening a B2B stakeholder taskforce.

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Take Back and Recycling

• Retailers will offer free take back sites will
  not need to be licensed for waste collection but
  will need to be registered
• Government in discussions with BRC on funding a
  retail compliance scheme (including support for
  upgrades to civic amenity sites. Govt expecting
  proposal on UK-wide collection network by May.
• The appropriate Agency will probably
  licence/permit WEEE treatment facilities
• WEEE will be a new approach to waste permitting
• Individual Producer Responsibility Government
  will pursue the Directives objectives.
  Government will establish taskforce to consider
  Individual Producer Responsibility in practice.

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Likely Costs of Compliance

• WEEE
• Registration fees
• Data provision NCH
• Take-back implications
• Re-design
• Labelling
• Compliance schemes
• Cost per tonne recycled
• Training

• RoHS
• Energy
• New equipment
• Supply-chain verification
• Re-testing of product
• Testing of new processes
• Higher supplier costs
• Component testing
• Training

• Fines?
• Staffing?

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Are you Ready?

• Do you understand how you are affected and what
  you need to do?
• Are you clear on when you need to do it by?
• Can you realistically achieve this?
• Can you estimate how much this will cost and make
  budgetary provisions?
• How will you provide the required financial
  guarantees?
• Will you go it alone or join a compliance scheme?
• Do you need assistance?

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Questions?