Chris,
1) The stated intention of the WEEE Directive was to foster PRODUCER
responsibility, not CUSTOMER responsibility - although all parties obviously
have their part to play in protecting the environment in which we live.
2) You may be familiar with the idea that EU Directives are EU-wide law
applied more or less consistently across all Member States - you can throw
that notion out of the window for the WEEE Directive. Each Member State must
have its own national legislation to implement the Directive (that's what
Directives 'direct' MSs to do) but here we have a Directive that is almost
anti-free movement in its effect. This is due to the variation in national
legislation and the associated ways each country has chosen to implement
requirements for producer registration etc. To give you another idea of the
different approach here, for every other Directive I am aware of 'placing on
the market' means placing on the market (e.g. offering for sale) in any MS
within the EU: not so with WEEED, 'put on the market' means put on that
particular country's market, so if you ship across the boarder from Northern
Ireland (part of the UK) to Southern Ireland (Eire) you take it off the UK
market (since you will no longer be recycling in that country and so will not
want to pay the recycling charge) but put it on to the Eire market (where you
will now be recycling it and so are liable for that country's - probably
different - recycling charge).
3) There are a couple of pan-European compliance schemes I am aware of (one
for lamps and the European Recycling Platform that has some large domestic
appliance and PC manufacturers as members): there may be more such schemes. I
do not know if even these schemes will operate in all 25 Member States. At a
quick glance, the URL that Samuel Lifshutz provided some information about
prospective compliance schemes in the UK, but as I have said there is much
variation here and few one-stop-shops for the whole of Europe. {And I say
'prospective compliane shemes' because the UK is late in implimenting the
Directive, so we have no national law that would cause compliance schemes to
come into existance yet - we're still at the planning ahead stage whereas some
countries have had laws in place for some time).
Simple this isn't.
Regards,
Richard Hughes
In a message dated 01/09/2005 18:03:00 GMT Standard Time, christine...@aol.com
writes:
Hi All,
We design telecom equipment in the US, it is manufactured by our CM's in
China, and we sell it into Euorope through our internal sales force which does
not have offices in Europe. Since our products are not sold to consumers, do
we have to worry about setting up a recycling program to meet the WEEE
directive? Currently, we are labeling our products with the Wheelie Bin and
providing verbiage in our manual stating we are WEEE compliant. We believe
that our end users/customers in Europe would be responsible for any Recycling
process /program.
Are we getting this right or do we need to contract with an EU authorized
agent to setup a collection / recycling program for our equipment.
Chris
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