Presentation on theme: "Overview of WEEE & RoHS Directives"— Presentation transcript:
1Overview of WEEE & RoHS Directives Michael BiggsHagerBEAMA MEMBERHAGER CHAIR WORKING GROUP ONWEEE & RoHS
2Why we know about WEEE & RoHS BEAMA sits on all relevant UK Govt working groups on both DirectivesBEAMA is a key member of ORGALINEThe European association for the electrical and mechanical industriesThe main liaison group with the European Commission including on WEEE and RoHS
3What we will cover today The technical backgroundTimescalesScope clarificationImplications for buyers
4Overview of WEEE & RoHS Directives Why two directives?Legal basesScopesImplementationRole of Orgalime
5WEEE & ROHS - legal bases WEEE directive is under article 175Article 175 directives specify minimum requirements.This gives the member states the possibility to go further in their own WEEE implementing legislation.Producer/putting on the market – national contextRoHS directive is an article 95.Article 95 requires same transposition across EUIntent of Article 95 is to avoid RoHS material bans being applied differently.Freedom to add to the WEEE scope does not extend to RoHSPutting on the market – EU context
6WEEE - what is covered?10 main categories: large household appliances; small household appliances; IT and telecoms; consumer equipment; lighting equipment (not household luminaires or filament light bulbs); electrical & electronic tools; toys, leisure & sports equipment; medical devices, monitoring and control instruments; and automatic dispensers.Equipment which is part of another type of equipment not covered by the directive is not itself in the scope.Components are not in the WEEED in their own right (only insofar as they are part of an equipment which is in, and are still attached when discarded.)
7RoHS - what is covered? All products in the WEEE Directive . Except medical equipment and monitoring and control equipment.Household luminaires & light bulbs are included.Otherwise, equipment not in the scope of WEEE is not in the scope of RoHS* either(*in the view of the Commission, UK Govt and several other member states.)
8RoHS implementationFrom 1 July 2006 producers cannot put on the EU market products falling in WEEE-scope categories 1,2,3,4, 5,6,7 and 10, plus domestic luminaires and light bulbs, which contain more than 0.1% by weight in homogenous materials, of: lead, mercury, hexavalent chromium, PBBs and PBDEs, and 0.01% of cadmium.There are some exempted applications of these substances, and requests for others.Categories 8 & 9 are not out of the scope indefinitely.NWML is the Govt-appointed enforcer.
9RoHS – what is not required Declarations of conformity are not required.Materials declarations are not required .Marking to indicate compliance is not required.The WEEE’s wheelie bin is not a RoHS compliance mark.Products which do not fall under RoHS do not have to meet its limits, nor do their component parts.It is completely legal to buy and sell such products & components.The responsibility for the product’s compliance with RoHS lies with the final product’s producer.The component supplier is not responsible for checking what his component is being purchased for.
10WEEE - Draft Requirements for producers Producers must join/be a schemeGet a registration number via schemeProvide registration number to distributors at time of saleWheelie bin, producer and date mark all in-scope WEEEReport B2C & B2B sales data separatelyMay handle B2C and B2B responsibilities separatelyProvide product informationKeep records for 6 yearsMay show visible fee.Envt Agencies are Govt-appointed enforcers
11WEEE – Draft UK Timetable for producers Issued for consultation 25 July 06 (closes 17 Oct)Laid before Parliament Dec 06Entry into force 1 January 07Join approved compliance scheme by 15 March 07Product marking/infn available from 1 April 07Provide registration number from 1 July 07Full producer obligations (B2B) from 1 April 07Full producer obligations (B2C) from 1 July 07B2C take-back from 1 July 07
12ORGALIMEOrgalime, the European Engineering Industries Association, represents 3 industrial branches (metal-working, mechanical engineering and electrical engineering) that manufacture over 27% of total EU manufacturing output (initial estimates put the industry's output at 1575 billion euro in 2005).Orgalime has 34 member trade federations in 23 European countries. The industry represents more than one quarter of the output and a third of the exports of the EU's manufacturing industries. It is the largest manufacturing sector in Europe, and the largest industrial employer in the EU25, providing some 10 million jobs.
13WEEE & RoHS - clarification of scopes Directives set out broad scopesindicative listsno comprehensive listssome grey areasManufacturer’s decision- must show due diligencemust work with other manufacturerspreferably at EU level
14WEEE & RoHS - clarification of scopes By working togethermfr agreement at product group leveladvice from DTICommission’s FAQsliaison with other EU mfrs throughSector Committees, andOrgalime WEEE task forceOur industry achievedcross-border product agreementResulting incross-border/cross sector mfr guidance
18Implications for buyers UK Govt Position Exact guidance on the RoHS directive can be given now – it is implemented in the UKExact guidance on the WEEE directive cannot be given now – it has NOT been implemented in the UKTherefore BEAMA and it’s members cannot give any guaranteed positions until the legislation is publishedTherefore advice given today on those product sectors that the industry believes to be in or out of scope are based on discussions thus farThere are some clear guidelines published in the recent UK consultation, but this is under discussion with the Commission
19Implications for buyers However….BEAMA expects that the majority of sectors within the BEAMA membership will conclude that they are out of scopeBased on the definition of a fixed installationSome sectors probably will be considered to be in scopeSome will definitely be in scope
20Implications for buyers Conclusions RoHS The legislation is in forceThe producers are responsible for complianceBEAMA members are all briefed on how to complySome product sectors outside the scope are choosing to meet the RoHS limits
21Implications for buyers Conclusions WEEE The decision on products being in or out of scope is with the company that places the product on the market ie not the wholesaler, distributor or installerBut if a wholesaler has own brands they become responsibleIn these cases we recommend that the company contacts the relevant trade bodies for the product sector to gauge opinions of other producersIf considered in scope the relevant compliance schemes are already in place