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WEEE regs interpretation
Posted: Fri Sep 08, 2017 11:38 am
by Elf&Safety
Hi all,
A moment of self doubt when understanding WEEE reg requirements. Basically the business is a contract electronics manufacturer, sell purely B2B, do not place onto market at all, produces nothing under it's own brand.
To what extent to the WEEE regs apply. My interpretation is that they are obligated to dispose of their WEEE waste properly, and that is all?
Re: WEEE regs interpretation
Posted: Sun Sep 10, 2017 4:36 pm
by Waterbaby
Bump
WB
Re: WEEE regs interpretation
Posted: Mon Sep 11, 2017 11:07 am
by Blackstone
Hi Elf,
I used to deal with all the WEEE issued at my last company and it took quite a while to get my head around it with lots of reading.
So just to understand a little.
The products manufactured would form part of another product that is placed onto the market by the other company?
for example your company make a circuit board that goes inside a washing machine and its the washing machine company/brand that has to register with a PCS and do all the compliance stuff?
Do the componants you make have any of your company branding/logo/name on them?
In the WEEE regulation interpretations,
http://www.legislation.gov.uk/uksi/2013 ... ion/2/made
“producer” means any natural or legal person who, irrespective of the selling technique used, including by means of distance communication in accordance with Directive 97/7/EC(17) of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts—
(a)
is established in a Member State and manufactures EEE under his own name or trademark, or has EEE designed or manufactured and markets it under his own name or trademark within the territory of that Member State;
(b)
is established in a Member State and resells within the territory of that Member State, under his own name or trademark, equipment produced by other suppliers, a reseller not being regarded as the “producer” if the brand of the producer appears on the equipment, as provided for in sub-paragraph (a);
I guess its all in the interpretations of the wording. Is the equipment marketed under the companies own name?
I would say if in doubt, contact a PCS and ask the question.
Hope that helps
Glen
Re: WEEE regs interpretation
Posted: Fri Sep 22, 2017 4:03 pm
by Elf&Safety
Sorry for the late reply..
Nope, not one mention of our company at all on any of our customers products. We are simply contracted to manufacture but then send back to our customer who will brand etc the manufactured goods.
I have basically setup a WEEE stream for electronic components, populated PCB board waste (although their is value in this), and old WEEE equipment like monitors etc... that is as far as i am taking it.