What does the WEEE Directive mean for UK Manufacturers, local authorities and Retailers?
Manufacturers
Under the Directive producers are legally and financially responsible for WEEE. Producers should consider the following issues:
- Registration as a producer with the enforcing authorities
- Joining a compliance scheme or producer/retailer consortium
- Data for compliance with reporting requirements
- Sales volumes and import/export information
- Details of weights of different products
- Customer split between commercial and retail
- Discussions with suppliers and subcontractors
Local Authorities
The Directive does not place any new burdens on local authorities. For example, there is no requirement for all Civic Amenity (CA) sites to offer separate collection of WEEE, and councils can apply for funding to upgrade CA sites to a designated collection facility (DCF).
Local authorities have responsibility for provision of data of tonnages collected and the reuse and recovery rates achieved from equipment that is donated to charities or sold to recyclers.
Retailers
The Directive states that retailers are to ensure that householders can return WEEE to stores free of charge on a one-for-one basis. This means that, from the commencement of the regulations consumers will have the right to take back their old product free of charge when going to a shop to buy a new like-for-like product. The Directive allows for alternative arrangements in lieu of take-back. Hence, it is likely that most UK retailers will direct consumers to local authority civic amenity sites and discharge the take back responsibility through membership of the Retail Compliance Scheme.
"Like-for-like" is understood to mean equipment that is of an equivalent type or fulfils the same function. This means that a customer might expect to be able to take back an old personal compact disc player when buying a new one. It also implies that an old cassette player could be returned when a compact disc player is being purchased, because both are used for the function of playing recorded music and sound.
The take-back obligations apply to all retailers, both those that specialise in selling electrical and electronic equipment and other retailers that also sell some electrical or electronic equipment as well as other goods.
Retailers can choose to offer in-store take-back schemes, or join an approved retailer compliance scheme that would undertake collection on its behalf.
It is recognised that large or bulky goods, such as refrigerators or television sets, although marketed via retail premises, are often delivered to customers and that an old product is collected when that delivery is made. Many retailers currently offer this arrangement as a service to their customers, and this is taken into account in the regulations. The Government appreciates that there will be continuing consumer demand for this service and that retailers will want to respond to this. These collections on delivery arrangements may be used in lieu of in-store take-back schemes provided the collection is free.
Distance sellers based in the UK, such as Internet sellers, who do not sell through retail premises, will be expected to offer an alternative free take-back service in lieu of in-store take-back schemes, or to join a retailer distributor compliance scheme.
Some EU Member States are proposing specific registration requirements for distance sellers. i.e. companies that sell directly to end users without using importers.
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