Presentation on theme: "Ronan Rafferty (MCIPS)"— Presentation transcript:
1 Ronan Rafferty (MCIPS) WEEE Directives (EAUC Seminar, University of Edinburgh, July 11th 2007)Executive SummaryRonan Rafferty (MCIPS)Purchasing SectionUniversity of Ulster
2 AimsSummarise the key points of the WEEE Regulations 2006 legislation.Highlight potential challenges and risks of a fundamentally changed landscape.Explore case studies evidence showing how other HE institutions are planning to tackle the issue.Hopefully provide the building blocks of a process which will enable the University to fully comply with the legislation.
4 What is the new WEEE legislation ? The Waste Electrical & Electronic Equipment Regulations 2006(EU WEEE Directive Transposed into UK Law)
5 A “good” EU Directive !Waste Electrical and Electronic Equipment (WEEE) Directive (2002/96/EC)&Restriction of Hazardous Substances in Electrical and Electronic Equipment (2002/95/EC)Implemented by the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2006
6 Main Players Government – DTi (responsible for implementation) DEFRA (approving authorised treatment facilities only)Environment Agency / SEPA / EHS (regulating compliance schemes)Businesses – producers and end users‘Compliance Schemes’RetailersLocal Authorities
7 Guidance Regulations finally came into force on 2nd January 2007 Producer responsibility began 1st July 2007Guidance available on DTi website
8 Why are (WEEE) Regulations 2006 Important? As of 1st July 2007 any organisation that buys or disposes of Electrical or Electronic Equipment (EEE) such as; IT, audio-visual, white goods or laboratory instrumentation must be in full compliance with the legislation.Legislation places responsibilities on institutions in relation to the recovery and recycling of all WEEE equipment.WEEE legislation raises issues concerning contract negotiations for the supply of new electrical and electronic equipment in terms of who takes responsibility for financing recovery and recycling.
9 ScopeAll equipment dependent on electrical currents or electromagnetic fields.10 indicative categories * :Large householdSmall householdIT and telecommunicationsConsumer equipmentLighting equipmentElectrical and electronic toolsToys leisure & sportsMedical devicesMonitoring equipmentAutomatic dispensersA non-exhaustive list of examples is also given in Schedule II of the Regulations at si2006/ htm#sch2.
10 Specific Exemptions Exemptions: Also: National security / military equipmentStationary industrial toolsLuminaries in householdsImplanted or infected medical productsEEE that forms part of equipment that is not in scopeFilament light bulbs and household luminaries (note that these are NOT exempt from RoHS)Also:Main power source must be electricityElectricity needed for primary functionNot part of another type of equipment or fixed installation
12 Producers and End-Users - The legislation makes producers of electrical and electronic equipment responsible for the financing of the recovery and recycling of such equipment at the end of life.- From 1st July 2007, in certain circumstances, the regulations also place responsibilities on end-users of WEEE to be responsible for the recovery and recycling of this equipment when it becomes waste.
13 Business User Obligations Business users will be responsible for some historic wasteWhat is Historical Waste?Waste products placed on the market before 13 August 2005Historical WEEE (placed on the market before 13 Aug 2005)If no like for like replacement the end business user is responsible for disposal costsIf like for like replacement of equipment – supplier (producer) responsibleNew Business WEEE (placed on the market after 13 Aug 2005)Producer responsible, unless otherwise agreed with business user
15 ChallengesDo your purchasing systems allow you to trace back when equipment was purchased and from whom?Determining when something was ‘placed in the market’ is likely to be problematicContacting / identifying historical suppliers to take away your historical waste may be problematicIdentifying ‘the Producer’
16 ‘Like for Like’ Fulfils the same function Need not be identical in all respectsTake account of technological developments and improvements in functionalityCommon sense / practical approachAcceptable examples: VCR – DVD, walkman / iPodUnacceptable examples: TV – drill, washing machine - kettle
17 Duty of CareAmendments under the Duty of Care have been recently consulted uponBusiness users would have to keep proof to demonstrate that one off consignments of WEEE have been disposed of to an accredited re-processorPractical considerations:Segregating WEEE from the main waste streamSeparating WEEE which is your responsibility and a producer / suppliers responsibility
18 Third Sector (Charities) If the equipment is still functional it is not waste and can therefore be given to charities ?Compliance Schemes encouraged to use charities and state how they will encourage the re-use of whole appliances in their applications
19 End Users Beware!The Regulations allow suppliers (producers) to negotiate alternative financing arrangementsThis will be a commercial decision and should form part of the supply contract negotiating processSome (unscrupulous!) producers may try and discharge their recycling obligation by writing into supply contracts that their customer is responsible for re-cycling WEEE at the end of its lifeContracts must be negotiated carefullyPurchasing Staff need to be made aware
20 Summary – 4 scenarios to plan for WEEE purchased before Aug 2005 that you are not replacing with like for like equipmentWEEE purchased before Aug 2005 that you are replacing with like for like equipmentWEEE purchased after Aug 2005 that you are not replacing with like for like equipmentNegotiations with suppliers for EEE purchased in the future
21 1. WEEE purchased before Aug 2005 that you are not replacing with like for like equipment Your responsibilityCompliance schemes can be used for one off collections of WEEE (or contact AATF directly)Many compliance schemes registered with the EA and specialise in different types of waste / different commercial situationsFind the most appropriate scheme for you (cost / evidence of proper disposal / IT equipment – confidentiality / destruction of sensitive data)Retain evidence of appropriate disposal via Duty of Care
22 2. WEEE purchased before Aug 2005 that you are replacing with like for like equipment Producer (new supplier) is responsible, regardless of whether they supplied you with the original equipmentContact new supplier and arrange collection of waste as well as delivery of new like-for-like equipment
23 3. WEEE purchased after Aug 2005 that you are not replacing Original producer (supplier) is responsible regardless of whether a like for like replacement is taking placeContact supplier and arrange collection (may need to get this information via your distributor)NB: Determining when something was ‘placed on the market’ may cause problems – in these situations, for practical purposes, establishments may want to make the executive decision to dispose of all historical EEE themselves, particularly given that many compliance schemes will collect free of charge
24 4. Future purchasing of EEE Ensure you address the issue of disposal of the equipment at end of life is included in the contractCan be used as an additional negotiating toolEnsure producers do not try and discharge end of life disposal obligations to you in the small printEnsure purchasing systems are set up to record dates of purchase and supplier information
25 Main points Possible producer obligations Register with a compliance scheme if necessaryMain obligation as business userEstablishing internal systems for understanding when waste electrical equipment was purchasedNegotiating supply contracts for future suppliesOne-off collections using a compliance scheme / AATFSeparation / storage of WEEEObtain evidence of correct disposal
26 Case Study 1 (University of Glasgow) The sheer scale of the challengeLack of awareness & understandingPurchasing and Legal requirementsAsset tracking and record keepingDisposalComplexity – large No. of people, depts & budgetsThe huge no. of items.Geographical/physical issuesThe cultureThe range of activities
27 Step 1 - Addressing awareness & understanding (University of Glasgow) Legal requirementsDuty of Care trainingSelection and audit of contractors for disposalEncourage use of existing approved contractors
28 Step 2 - Addressing administrative & management issues (University of Glasgow) Encourage linking to PAT and assets register databases.Utilise Agresso financial recordsEducate departments on retention of Transfer Notes. Periodic audit of departments.
29 Step 3 – Addressing Disposal (University of Glasgow) Uplifts from each department and buildingEnvironmental and sustainability issues a high priority. The issue of charitiesCosts associated with these small uncoordinated uplifts
30 Step 3 – Addressing Disposal (University of Glasgow) Disposal of highly specialist equipment on a case by case basis initiallyReview disposal quantities and costs after ~18 monthsTender for framework agreement for disposals
31 Case Study 2 (University of Exeter) PROCUREMENT INFLUENCES:-CommunicationWaste Matters – Environmental SeminarSustainability Committees’Appointment of Sustainability AdviserWEEE ‘round-up’s’ (2006)Tender clauseContract Waste / Recycling Solution
32 OBJECTIVES (Exeter) WEEE Audit Partnering Arrangements Reduction in Carbon Footprint / Co2 emissionsAdvantages / Quick WinsLease / Rental IT Equipment UoPProcurement Strategy of how we intend or propose to comply with the WEEE Regulations
33 Case Study 3 (University of Edinburgh) Objectives:-To make the purchasers and end users of equipment aware of the WEEE Directive and of our responsibilities and challengesTo ensure that the suppliers who deliver to the University have registered with a scheme (e.g. Valpak) - only 30% done so to dateTo ensure that WEEE is disposed of at the lowest cost to the University whilst conforming to DoC / good practice
34 Our Challenges Awareness of users/purchasers No common inventory of items under £25kUnauthorised / unregistered equipmentUnauthorised disposal methods (skip, charities)Disposal costs (who? / when?)Quantity and variety of WEEEDetails of compliance schemes geographical and space constraints