One-Stop-Shop for your compliance. WEEE Directive Open Scope. Obligations and (new) challenges on European level. WEEE Europe AG

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1 One-Stop-Shop for your compliance WEEE Directive Open Scope Obligations and (new) challenges on European level WEEE Europe AG

2 Agenda 1. WEEE Legislation and challenges in international context 2. WEEE Europe Service Portfolio to simplify European Compliance WEEE Europe AG

3 Agenda 1. WEEE Legislation and challenges in international context 2. WEEE Europe Service Portfolio to simplify European Compliance WEEE Europe AG

4 WEEE Recast and Open Scope???? In 3 months a fundamental change of legislation gets into force 10 categories to be replaced by 6 new ones Possibility of allocation to one of the 10 categories is no criteria any more for in / out - decision All electrical Products in scope if not subject to an exemption European WEEE Directive 2012/19/EU Producer is responsible to proof that he is not affected, very narrow interpretation of the law is required WEEE Europe AG

5 What are the products in scope? In a nutshell: Products that require electrical current or electromagnetic fields for operation or equipment for the generation, transfer and measurement of such currents and fields < 1000V (AC) or < 1500V (DC) Are not subject to a legal exemption WEEE Europe AG

6 What are the products in scope? 10 Product Categories Large Household Appliances Small Household Appliances IT- and Telecommunication Consumer Electronics / Photovoltaic Lighting Equipment Electrical and electronic Tools Toys / Leisure- und Sports Equipment Medical Appliances Monitoring and Control Equipment Automatic Dispensers WEEE Europe AG

7 What are the products in scope? As from => open scope, 6 Categories 1. Temperature Exchange Equipment 2. Screens, Monitors and equipment containing screens having a surface greater than 100 cm 2 3. Lamps 4. Large Equipment 5. Small Equipment 6. Small IT and telecommunication equipment (no external dimension more than 50 cm) WEEE Europe AG

8 Important Issues to keep in mind Extension of scope to all Electrical and Electronic Equipment (excluding few specific exemptions) from onwards Replacement of the previous 10 categories to 6 new ones Equipment to be used both in households and by professionals (Dual use) is considered B2C Increase of targets for collection and recycling rates (choose the right partner!) Possibility of appointing a natural or legal person as Authorised Representative to ensure the obligations of Producers established in another Member State WEEE Europe AG

9 How does the shift to six categories work? WEEE Europe AG

10 Large or small equipment? WEEE Europe AG

11 Who is producer? WEEE Europe AG

12 What are the relevant obligations? Responsibility of producer for the whole product lifecycle Registration to national WEEE/Battery Register Financing of collection and recycling of electronic waste (WEEE) / Financing guarantees Put on the market declarations European WEEE Directive 2012/19/EU Take-back of WEEE (0:1 / 1:1) individually or collectively Information obligations The WEEE Directive refers to the principle of Extended Producer Responsibility (EPR) WEEE Europe AG

13 Important deviations Open Scope Start date for the Open Scope deviates in some of the Member States: 1. Start date already for the Open Scope already from : 1. Bulgaria 2. Hungary 3. Poland 4. Slovenia 2. Start date for the Open Scope only from : 1. UK WEEE Europe AG

14 Which exemptions exist? Currently (according to Article 2.3 WEEE Directive) equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes equipment which is specifically designed and installed as part of another type of equipment that is excluded from or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment filament bulbs WEEE Europe AG

15 Which exemptions exist? In addition as from (according to Article 2.4 WEEE Directive) equipment designed to be sent into space large-scale stationary industrial tools large-scale fixed installations, except any equipment which is not specifically designed and installed as part of those installations means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved non-road mobile machinery made available exclusively for professional use equipment specifically designed solely for the purposes of research and development that is only made available on a business-to-business basis medical devices and in vitro diagnostic medical devices, where such devices are expected to be infective prior to end of life, and active implantable medical devices WEEE Europe AG

16 Specifically designed as part of another equipment What type of equipment falls under the exclusion in Article 2(3)(b) as specifically designed and installed as part of another equipment? If equipment is specifically produced in order to be installed as part of another type of equipment that is excluded from or does not fall within the scope of the Directive and can fulfil its function only if it is part of that equipment, such equipment is specifically designed and falls out of the scope of the Directive (Article 2(3)(b)). In these cases specifically designed equipment means that it is tailor made since it is designed to meet the needs of a specific application in the equipment that it is part of. (EU COM WEEE FAQ Document) WEEE Europe AG

17 Specifically designed as part of another equipment What type of equipment falls under the exclusion in Article 2(3)(b) as specifically designed and installed as part of another equipment? Examples of specifically designed equipment to be installed as part of another type of equipment that is excluded from the scope of the Directive include: equipment specifically designed, dimensioned and customized to be used as part of a specific large-scale fixed installation ( LSFI ) (e.g. sensor equipment with a size, electrical interface and mounting features designed to fit inside drill heads). equipment designed specifically to be installed as part of a large-scale stationary industrial tool LSSIT (e.g. pumps designed for transport of cooling lubricants for LSSIT) (EU COM WEEE FAQ Document) WEEE Europe AG

18 Specifically designed as part of another equipment What type of equipment falls under the exclusion in Article 2(3)(b) as specifically designed and installed as part of another equipment? Examples of specifically designed equipment to be installed as part of another type of equipment that does not fall within the scope of the Directive include navigation devices designed for specific models of cars and incorporated into the car and galley equipment designed for an individual aircraft or range of aircraft. Conversely, equipment intended to be fitted, for example, to any automobile such as hands-free phone systems and retrofit satellite navigation devices is not specifically designed and does not benefit from this exclusion. (EU COM WEEE FAQ Document) WEEE Europe AG

19 Product examples in scope? Is this an LSFI? WEEE Europe AG

20 Large Scale Fixed Installation (LSFI) LSFI means a large size combination of several types of apparatus and, where applicable, other devices, which: (i) are assembled, installed and de-installed by professionals, (ii) are intended to be used permanently as part of a building or a structure at a predefined and dedicated location, and (iii) can only be replaced by the same specifically designed equipment. Large Scale if at least one of the criteria is met: (i) Weight more than 44 Ton; (ii) Larger than 5,71m x 2,35m x 2,39m (length, height and width); (iii) Heavy-duty cranes are needed for installation or de-installation; (iv) Building needs structural modification; (v) Rated power greater than 375 kw. WEEE Europe AG

21 Large Scale Fixed Installation (LSFI) WEEE Europe AG

22 Large Scale Fixed Installation (LSFI) WEEE Europe AG

23 Scope Tools Drilling machines - both in scope? or exempted as LSSIT? WEEE Europe AG

24 Large Scale Stationary Industrial Tools (LSSIT) The definition of LSSIT consists of three specific prerequisites: (i) assembly of machines, equipment, and/or components, functioning together for a specific application ( tools ); (ii) permanently installed and de-installed by professionals at a given place and used and maintained by professionals in an industrial manufacturing facility or research and development facility; (iii) and large size. All three prerequisites must be met for the exclusion to apply. Since there is no metric guidance that defines large-scale subject to LSSIT, EWRN proposes to introduce the following metrics as an orientation: (i) Weight: more than 2 tons (ii) Volume: minimum of 15,625 m3 (e.g. 2,5 m x 2,5 m x 2,5 m) Both metrics must be met! WEEE Europe AG

25 Large Scale Stationary Industrial Tools (LSSIT) WEEE Europe AG

26 Explanations related to the exemptions FAQ WEEE2 / FAQ RoHS2 / EWRN Position Papers WEEE Europe AG

27 Scope additional examples... In scope? Dependent on electric currents or electromagnetic fields in order to work properly means that the equipment needs electric currents or electromagnetic fields (e.g. not petrol or gas) to fulfil its basic function (i.e., when the electric current is off, the equipment cannot fulfil its basic function). If electrical energy is used only for support or control functions, this type of equipment is not covered by the Directive. Examples of equipment that does not need electricity to fulfil its basic function, (but only requires, for example, a spark to start), include petrol lawn mowers and gas stoves with electronic ignition only Source: FAQ WEEE Directive WEEE Europe AG

28 Scope additional examples... In scope? Components cover the range of items that, when assembled, enable an EEE to work properly. Components placed on the market separately in order to be used to manufacture and/or repair an EEE fall outside the scope of the Directive unless they have an independent function themselves. Source: FAQ WEEE Directive WEEE Europe AG

29 Scope additional examples... Scope? Whole toilet or toilet seat only? Water filter: Shower with light & music, controlled via a box: Boiler Electronic Tap: WEEE Europe AG

30 Scope additional examples... WEEE Europe AG

31 Scope Installation Equipment Source: CECAPI European Committee of Electrical Installation Equipment Manufacturers ; WEEE Europe AG

32 Open Scope - cables FAQ 3.8. Antennas and cables used for the transfer of electrical currents and electromagnetic fields meet the definition of EEE as set out in Article 3(1)(a) and thus fall within the scope of the Directive. However, cables that are components of another EEE (either internal permanently attached or externally connected and removable, but sold together or marketed/shipped for use with the EEE) do not fall within the scope of the Directive. Cables placed on the market individually that are not part of another EEE are considered as EEE themselves. Quelle: FAQ EU Kommission WEEE Europe AG

33 Open Scope - cables FAQ Is equipment such as IT and telecommunication equipment used within a large-scale fixed installation or a large-scale stationary industrial tool excluded from the scope? This depends. Equipment which is not specifically designed and installed as part of an excluded installation or tool is not excluded from the scope. Smoke detectors, computers and cables are examples of equipment that is in scope. Only if for example a computer is specifically designed for a large-scale installation or tool, (e.g., an industrial PC to be integrated in and attached with the large-scale fixed installation), and if that computer can only function and be used within the large-scale fixed installation (because of its special hardware and/or construction), it is excluded as part of a large-scale fixed installation. If not placed within the large-scale fixed installation, such a computer has no possible functionality or use of its own. WEEE Europe AG Quelle: FAQ EU Kommission

34 One Directive different implementations The different implementations challenge producers in three different ways: 1. How do I need to interpret the differences in the countries? 2. How can I ensure compliance in all states as multinational producer? 3. How can I efficiently arrange for the different Put on the Market declarations in the various countries? WEEE Europe AG

35 Agenda 1. WEEE Legislation and challenges in international context 2. WEEE Europe Service Portfolio to simplify European Compliance WEEE Europe AG

36 Shareholders and Partners Who is WEEE Europe? WEEE Europe AG

37 Who is WEEE Europe? WEEE Europe AG is a Joint Venture of leading European Take-back systems as onestop shop solution Non-for-profit organisation located in Munich WEEE Europe AG

38 How can we help you? 4 Steps to Compliance for new producers WEEE Europe AG

39 WEEE Europe Time-saving: Professional administration of your productportfolio regarding WEEE & Battery- Compliance Effective & cost-efficient: Central PoM declaration via one Online- Platform Sustainable: Producerowned non for profit take-back systems Access to long-year experience of national specialists Advantage: Central contact person, B2B & B2C Excellent price / performance ratio Product Allocation PoM Reporting Contract Handling The best Take Back Schemes in Europe in a One Stop Shop approach Non for profit 50% of the European E-waste treated through WEEE Europe Partners (ca. 1,5 Mio tons per year) Professional Support by the Central Office together with the National Specialists Assessment Consulting WEEE Europe AG

40 weee can manage challenges together, get in contact for support! WEEE Europe AG Konrad-Zuse-Platz 8 D Munich Tel.: info@weee-europe.com WEEE Europe AG