B2B sector – producer's responsibilities

B2B Sector – the user/last holder responsibilities

B2B sector – producer's responsibilities

In the B2B sector the producers have a number of obligations under the WEEE directive. This assumes the products supplied are deemed to be within the scope of the directive.

•  Producers are responsible for the collection and treatment costs for ALL WEEE put on the market after 13 th August 2005 .

•  Producers are responsible for the collection and treatment costs for all historic WEEE, on a one for one basis if they supply a new product, otherwise the LAST Holder is responsible.

•  The financial guarantees discussed in Article 8 do not apply to the Producers who are solely supplying in the B2B sector.

•  Producers are still required to mark their products as described in the directive to demonstrate their compliance. A new Cenelec standard is available from BSI number BSEN50419

•  Producers are also obliged under the WEEE directive to provide basic information on material content and the re-use/treatment requirements to the treatment facilities. RID UK Ltd suggests this issue is discussed with the Treatment facility in advance as they may not require this information or the requirement may be minimal.

Producers who have to comply with the directive may choose to get involved in WEEE collection themselves or through joining a compliance scheme, who will collect WEEE on their behalf. However registration and reporting to the Environment Agency has to be through a scheme.

If producers wish to go it alone they will have to register as a producer scheme with the enforcement authority and then they will have to take end of life EE goods back from their customers for onward treatment and recycling. It could be that a producer may involve their distributors in this who will collect old equipment when they sell new equipment. RID UK Ltd can help here by providing collections from producers or distributors premises and recycling/treatment of the equipment thereafter.  Producers are further obliged to report evidence of correct treatment and evidence of meeting recovery/recycling targets.  RID UK can also assist with this.

Where companies do not want to setup their own compliance scheme they may wish to still get involved in their own collections but join a scheme simply for reporting with the Environment Agency.

RID UK fully support the new proposed exemptions to allow storage of WEEE equipment prior to collection from an authorised treatment facility. This is a practical solution that can allow producers to take back product and consider individual producer compliance.

Alternatively producers can still join a full open compliance scheme. Joining such a scheme means that ALL these responsibilities are taken on by the scheme. When clients have equipment to be collected/treated they would inform the collective who would arrange for collection/treatment without the producer getting involved. An example of such a scheme can be seen on the website www.b2bcompliance.co.uk

B2B Sector – the user/last holder responsibilities

Whilst the WEEE directive is a producer responsibility directive, the end user/last holder of the waste EE equipment does have some level of responsibility.

• Under the revision to article 9 of the WEEE directive the user/last holder of WEEE is responsible for any historic waste unless they are buying a new product in which case the old item becomes the responsibility of the producer.

• If the last holder takes responsibility for the WEEE then they are also responsible for reporting the evidence of treatment and recovery / recycling to the relavent authorities.  RID UK can assist end users with this.

 

• Even if the EE waste is not classed as WEEE under the directive the user/last holder of EE waste may have to segregate their EE waste from general waste and find alternative routes under changes to the Landfill and Hazardous waste directives. Existing waste contractors may not remove non segregated EE waste from site as general waste. Please see our section on other legislation for more details.

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