The Waste Electrical and Electronic Equipment (WEEE) directive - impacts on it disposal, re-use and recycling


2 December 2004, source RDC

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Effective management of an organisation's Used and Surplus IT equipment can lead to significant residual value being achieved - that can be reinvested into newer technology and environmentally responsible recycling offend-of-life equipment. Insufficient knowledge of the obligations of current and pending legislation surrounding the disposal of used IT assets places an organisation at risk of prosecution, public embarrassment and, for individuals, fines or even imprisonment. UPDATE

THE WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT (WEEE) DIRECTIVE - IMPACTS ON IT DISPOSAL, RE-USE AND RECYCLING.

Effective management of an organisation's Used and Surplus IT equipment can lead to significant residual value being achieved - that can be reinvested into newer technology and environmentally responsible recycling offend-of-life equipment. Insufficient knowledge of the obligations of current and pending legislation surrounding the disposal of used IT assets places an organisation at risk of prosecution, public embarrassment and, for individuals, fines or even imprisonment.

This Paper aims to provide an overview of some of the key elements of the WEEE Directive with a summary of the impacts on your organization.

The Waste Electrical and Electronic Equipment (WEEE) Directive was adopted by the European Union of 13 February 2003.

PURPOSE OF THE WEEE DIRECTIVE

The Directive aims to:
  • Reduce the waste arising from electrical and electronic equipment
  • Improve the environmental performance of all those involved in the life cycle of the electrical and electronic equipment.


    • WHY WEEE?

    Computers contain materials chosen for their functional performance, which when disposed of are harmful to human health and the environment.

  • CRT Monitors may contain over 2 kg of lead in cathode ray tubes
  • Mercury is used in switches
  • Cadmium, a carcinogen, is used in cathode ray tubes, plastics and circuit boards
  • Some flame retardant chemicals can affect reproductive systems

    A 1998 study indicated the EU produced 6 million tonnes of WEEE a year, over 90% of which was landfilled or incinerated without any pre-treatment to remove the hazards. WEEE is also the fastest growing element in the waste stream, growing at 12% per annum. Landfilled WEEE risks polluting water supplies; incinerated WEEE risks airborne particle pollution.

    TIMETABLE

    The WEEE Directive must be transposed into member states laws and be in effect by August 13th 2005. Fines and imprisonment can be imposed for breeches.

    UK Timetable:

  • 29 October 2004 - WEEE Consultation by UK Government (see below).
  • 01 January 2005 to 12 August 2005 - Producers obliged to register.
  • 13 August 2005 - Producer & Distributor obligations begin.
  • January 31 2006 - Deadline for obligated companies to report compliance for the period 13 August 2005 to 31 December 2006 (thereafter becoming annual January to December).
  • July 2006 - Registration by producers of RoHS compliant EEE to be placed on market in EU.
  • 2008 - targets to be set for reuse.







    WEEE CONSULTATION

    The UK Government has several consultations listed below (with web links to download copies of the consultation documents).

  • DTI WEEE & RoHS consultation: - www.dti.gov.uk/sustainability/weee/#Consultation_on_Government_implementation

  • Environment Agency WEEE treatment consultation: -
    www.environment-agency.gov.uk/commondata/105385/weee_consult_833453.pdf

  • DEFRA Hazardous Waste consultation: -
    www.defra.gov.uk/corporate/consult/wastreg-haz/index.htm


    WHAT IS WEEE?

    WEEE is electrical or electronic equipment that is dependent upon electrical currents or electromagnetic fields under 100 volt AC or 1500 volt DC. It includes all components, sub-assemblies and consumables that form part of a product at the time it is discarded as waste. There are ten categories of WEEE: -

    Large household appliances
    Small household appliances
    IT, Telecom & Office
    Consumer
    Lighting
    Tools
    Toys
    Medical devices
    Monitoring & control
    Automatic dispensers

    WHAT IS WASTE?

    An item becomes waste when it is discarded and falls out of the normal chain of commercial utility, even if it has a positive value - such as computer motherboards.

    SHOULD ALL USED IT BE CONSIDERED AS WASTE UNDER DIRECTIVE?

    The WEEE Directive Article 1 specifically encourages the reuse of equipment. Re-use is favoured environmentally because reduces the amount of resources consumed. A study by a leading waste management company estimates that for every ton of equipment produced, up to ten tons of resources have been consumed. Re-use at a lower, second-user price also offers opportunities for affordable access to IT for business and domestic users.

    DOES WEEE IMPACT ON DESIGN OF EQUIPMENT?

  • A "daughter" directive to the WEEE Directive, the Restriction of Hazardous Substances Directive (RoHS), is an attempt to remove hazardous materials from EEE.
  • By 1st July 2006, all new EEE put on the market should not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).
  • Products that do not comply will be banned from sale within the EU.
  • Exemptions for use of the restricted substances can be applied for in medical equipment, monitoring and control equipment and use in spare parts for items put on the market before 1 July 2006. Several exemptions are listed in the RoHS Directive proposals.

    HOW DOES DIRECTIVE AFFECT DISPOSAL OF USED IT ASSETS?

    The WEEE Directive aims to increase reuse of equipment and to minimise the environmental impact of all waste equipment. This is done in several ways - the figures in parentheses refer to the Articles of the WEEE Directive published 13 February 2003: -
  • Encouraging the reuse of used equipment and components (A1).
  • WEEE to be separately collected from other waste streams (A5).
  • Retailers to offer free take back of like for like products (A5).
  • Only approved recyclers to be used to treat WEEE using best available techniques (A6).
  • Pre-treat before disposal - cathode ray tubes, batteries, toner cartridges, and flame retardant plastics.
  • Setting specific targets for IT, these are to recycle 65% and recover 75% by weight of IT discarded as waste (A7).
  • Producers to pay for recovery and recycling of WEEE from private households (A8) - this is the "producer responsibility" principle that underpins the WEEE Directive.
  • Users other than private households (e.g. business and public organisations) can agree that either producers, distributors or users take responsibility for WEEE (A9).

    WEEE PRODUCER RESPONSIBILITY

  • This is a key theme of the WEEE Directive, based upon the principle that those who produce products also select the materials and components used and so should face the financial consequences of their decisions. In the past, the taxpayer has traditionally picked up such costs, without being able to influence the design and selection of materials in products purchased for their function.
  • A Producer is a business that manufactures, imports or sells under its own brand, any EEE, with a few listed exceptions such as equipment for national security and large industrial plant.
  • From early 2005 all Producers will be required to register details of their company and supply data relating to the amount of EEE placed on the market in 2004.
  • From 13th August 2005, Producers will have to finance the collection, treatment and processing of WEEE and produce evidence that they have met the recycling and recovery targets set. They will also have to demonstrate that financial provision has been made for the collection, treatment and processing of post August 2005 products, unless the company has registered with a compliance scheme.
  • For equipment supplied to Business Users after 13 August 2005 Producers will finance collection, treatment and recycling or disposal, unless alternative arrangements have been made with the user. This latter arrangement is designed to encourage businesses to consider reusing equipment by reselling to earn extra revenue - a significant possibility for IT WEEE in particular.
  • For equipment supplied up to 13 August 2005, producers are only responsible for financing the removal of equipment on a like for like basis.
  • Producers will ensure products are labelled or marked with WEEE symbols (a crossed out wheelie bin).
  • Producers must provide information on components that can be reused or recycled.
  • Producer shall keep records on the mass of components and materials that enter (input) and leave (output) the treatment facility and / or when entering the recovery or recycling facility.

    USER RESPONSIBILITY

    Business users must separate WEEE from other waste and ensure it is passed for treatment to an appropriately treatment facility.

    Up to 13th August 2005, "Historic WEEE" (items placed on the market before this date) can be collected freely by distributors on a one-for-one, like-for-like basis. This means that anyone buying, say 50 computers, can expect the distributor to collect up to 60 PCs or any other computer items, free of charge. If the user does not have or wish to dispose of their used EEE at this time, then they will be responsible for its disposal when they do decide to discard the items. Treatment of WEEE and reporting on recycling and compliance will follow the same requirements as for Producers.

    WEEE DISTRIBUTOR / RETAILER RESPONSIBILITY

  • Distributors and retailers selling EEE (defined as anyone supplying products on a commercial basis) will have to offer like-for-like in-store take-back from 13th August 2005 or register and contribute to a central fund or compliance scheme.
  • Retailers & Distributors can pass items collected under take-back schemes to producers free of charge for recycling and disposal.
  • The WEEE permitting requirements remain to be clarified by DEFRA, as currently any sites receiving waste must hold a current and valid permit to do so. The current licensing regime is under review and proposals are in hand to simplify registration of retail units receiving WEEE for transfer to appropriately licensed recyclers or disposal organisations.
  • Retailers may participate in a compliance scheme, paying a registered compliance scheme to manage their WEEE obligations.

    WEEE OBLIGATIONS TRANSFER BY NEGOTIATION

  • Users & Producers can conclude an agreement whereby users or another party take on liability for WEEE recovery and recycling costs, encouraging reuse sales. Remarketing revenue encourages reuse, which is more environmentally friendly than recycling.
  • This clause facilitates the reuse and remarketing of WEEE by third parties other than producers. Many organisations have developed that offer asset management services to refurbish, remarket and or recycle used EEE, especially used IT equipment. RDC is one such company.
  • RDC manage clients' business risks by electrical safety testing used equipment, eradicating data to standards approved by HM Government Security Services and remarketing to customers worldwide via several established marketing channels. Users & Producers can conclude an agreement whereby users or another party take on liability for WEEE recovery and recycling costs, encouraging reuse sales. Remarketing revenue encourages reuse, which is more environmentally friendly than recycling.

    WEEE RECYCLING & REUSE TARGETS

    Large White goods - recover 80% by weight, Recycle 75%
    IT & telecoms recover 75% & recycle 65% by weight
    Gas discharge lamps, 80% recovery
    Remaining WEEE 70% recovery, 50% recycling

    To "recover" means to recycle materials or treat by waste to energy incineration - excluding incineration that involves merely burning to dispose of the waste.

    ARE THE IT WEEE TARGETS OF RECYCLING 65% AND RECOVERING 75% BY WEIGHT ACHIEVABLE?

    Yes - RDC has been tracking the mass balance of material sent into recyclers and the amount of material recovered and sent to landfill as waste since 1997. From April 2002, RDC has achieved zero landfill for IT waste with 92% materials recycling and the remaining 8% reclaimed by waste to energy incineration - giving 100% recovery. RDC reports material mass balance for clients' IT equipment recycled using our purpose designed relational database.

    WHO IS APPROVED TO RECYCLE WEEE?

    The Directive requires WEEE treatment operations be issued with a permit by the appropriate authority (Environment Agency/SEPA). Certification to Environmental Management Systems (e.g. ISO 14001, EMAS) is stipulated (A6), although the DTI are reluctant to proceed with standards as few UK recyclers are certified - unlike their European counterparts. RDC are already certified to ISO 14001 and audit our recyclers to verify their processes and permits are valid.

    HOW DOES RDC ENSURE CLIENTS' COMPLY WITH WEEE AND OTHER IT LEGISLATION?

    RDC has developed a one-stop shop that can demonstrate compliance to all above legislative requirements - an innovative approach that won RDC the award of the prestigious Queens' Award for Enterprise for Innovation in 2002.
  • Recovery of used IT from the UK - plus European and worldwide clients' sites.
  • Removal of client data - eradicated up to UK Government security requirements.
  • Removal of operating system and new licensed software added as required -RDC are members of the Federation Against Software Theft (FAST).
  • Refurbishment - electrical safety and functionality testing is carried out using processes certified to the international quality management standard, ISO 9001.
  • Reassuring new users - RDC offer warranty on reused equipment.
  • Redeployment of upgraded and reconfigured equipment within organizations saves on purchase of new equipment.
  • Remarketing to the second-user, consumer, trade and international markets generating revenue for business.
  • Recycling and recovery of all IT equipment with zero landfill - using audited best available techniques. RDC are certificated to the International Environmental Management System, ISO 14001.
  • Reporting using RDC's purpose designed database, on each load and each item processed, what is passed for reuse, what is sold or redeployed, what is sent for recycling and what is the mass balance of materials reclaimed during the recycling process. The Environment Agency reported 100% computer reuse and recycling using RDC in their Environmental Report for 2002/03.
  • RDC won the Gold and Silver Green Apple Awards for recycling, awarded by the Institute of Waste Management in 2003.
  • Reassurance - all of RDC's IT asset management operations are independently assessed.
  • RDC are the first Used IT Asset Management company to achieve the BSI's 'Integrated Management System' incorporating the International Environmental Management Standard ISO 14001, the International Quality Management Standard ISO 9001:2000 and the Occupational Health and Safety guidelines, OHSAS 18001.
  • RDC won the Royal Mail Gold Supplier Award for Sustainable Development in 2003.

    For further details about RDC, either visit the RDC web site http://www.rdc.co.uk or call RDC on 01376 504 640.




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