In At The Bleep End
Saturday, June 30, 2007
Clear and practical guidance on WEEE compliance for I.T. departments is hard to come by. The following are some questions I asked of the "WEEE Team" and their answers (in blue).
"We are a small/medium sized company who use IT equipment but don't sell it (a Non-household end user).
1. I read that some producers will sell lower cost equipment where the WEEE responsibility is transferred to the buyer. How will we know before we commit to purchase?
The seller can not transfer this responsibility to you without prior agreement. This is a commercial decision whether the buyer wants to deal with the EEE at the end of its life.
2. If we buy new equipment to replace old, do we have to prove this is the case, and that we aren't just taking advantage of the legislation to offload old junk that was lying around? If so, how?
Producers will have obligations for "historical" - that is placed on the market prior to 13 August 2005 and "new" - that is placed on the market after 13 August 2005. Producers are responsible for the collection and treatment of historical WEEE that is being replaced on a like-for-like basis. If old items are pre 13 August 2005 and you are replacing it with new then the Regulations state that the producer has to pay for its recycling. They would not however, be responsible for taking away a old fax machine if you were replacing it with a new PC.
3. If we buy new equipment via online resellers, eg. www.ebuyer.co.uk, how do we indicate at the point of purchase that this is to replace old equipment which will need to be collected? Or do we have to phone the original manufacturer after sale and delivery to say "now, come and get the old PC please"?
Yes, when buying from an internet website, the EEE remains the responsibility of the producer who has to be registered with a producer compliance scheme and will need to have provided the retailer with their registration number to demonstrate their compliance with the Regulations. You will need to contact the producer or their compliance scheme to arrange collection of old EEE.
4. If we need to dispose of but not replace IT kit, how do we go about arranging for collection and treatment? How much is this likely to cost?
If a business end user wishes to discard items of historical EEE without replacing the item it is their responsibility and they are bound by existing the Environmental Protection Act and Duty of Care. You have an obligation to ensure that WEEE is being collected and treated by someone who has a Waste Management Licence. Your council may have details.
{Note: Our local council said they don't have anything in place for dealing with or collecting WEEE at all, then pointed us at a private service charging £50 a time}
5. I read one IT guy saying they had to apply for something like a 'Hazardous Waste Disposal Number'. Is this correct?"
Operators storing, repairing or refurbishing WEEE will need to apply for a Waste Management Licence. Further details of how this applies is covered on the QS 19 of the EA FAQ. More specific questions about WML should be directed to the EA National Consumer Contact Centre tel 08708 506506."
