1. Ronan Rafferty (MCIPS)
WEEE Directives (EAUC Seminar, University of Edinburgh, July 11th 2007)
Executive Summary
Ronan Rafferty (MCIPS)
Purchasing Section
University of Ulster

2. Aims
Summarise 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.

3. WEEE MAN

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’
Retailers
Local Authorities

7. Guidance Regulations finally came into force on 2nd January 2007
Producer responsibility began 1st July 2007
Guidance 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. Scope
All equipment dependent on electrical currents or electromagnetic fields.
10 indicative categories * :
Large household
Small household
IT and telecommunications
Consumer equipment
Lighting equipment
Electrical and electronic tools
Toys leisure & sports
Medical devices
Monitoring equipment
Automatic dispensers
A 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 equipment
Stationary industrial tools
Luminaries in households
Implanted or infected medical products
EEE that forms part of equipment that is not in scope
Filament light bulbs and household luminaries (note that these are NOT exempt from RoHS)
Also:
Main power source must be electricity
Electricity needed for primary function
Not part of another type of equipment or fixed installation

11. DTi Guidance - Scope

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 waste
What is Historical Waste?
Waste products placed on the market before 13 August 2005
Historical WEEE (placed on the market before 13 Aug 2005)
If no like for like replacement the end business user is responsible for disposal costs
If like for like replacement of equipment – supplier (producer) responsible
New Business WEEE (placed on the market after 13 Aug 2005)
Producer responsible, unless otherwise agreed with business user

15. Challenges
Do 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 problematic
Contacting / identifying historical suppliers to take away your historical waste may be problematic
Identifying ‘the Producer’

16. ‘Like for Like’ Fulfils the same function
Need not be identical in all respects
Take account of technological developments and improvements in functionality
Common sense / practical approach
Acceptable examples: VCR – DVD, walkman / iPod
Unacceptable examples: TV – drill, washing machine - kettle

17. Duty of Care
Amendments under the Duty of Care have been recently consulted upon
Business users would have to keep proof to demonstrate that one off consignments of WEEE have been disposed of to an accredited re-processor
Practical considerations:
Segregating WEEE from the main waste stream
Separating 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 arrangements
This will be a commercial decision and should form part of the supply contract negotiating process
Some (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 life
Contracts must be negotiated carefully
Purchasing 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 equipment
WEEE purchased before Aug 2005 that you are replacing with like for like equipment
WEEE purchased after Aug 2005 that you are not replacing with like for like equipment
Negotiations 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 responsibility
Compliance 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 situations
Find 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 equipment
Contact 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 place
Contact 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 contract
Can be used as an additional negotiating tool
Ensure producers do not try and discharge end of life disposal obligations to you in the small print
Ensure 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 necessary
Main obligation as business user
Establishing internal systems for understanding when waste electrical equipment was purchased
Negotiating supply contracts for future supplies
One-off collections using a compliance scheme / AATF
Separation / storage of WEEE
Obtain evidence of correct disposal

26. Case Study 1 (University of Glasgow)
The sheer scale of the challenge
Lack of awareness & understanding
Purchasing and Legal requirements
Asset tracking and record keeping
Disposal
Complexity – large No. of people, depts & budgets
The huge no. of items.
Geographical/physical issues
The culture
The range of activities

27. Step 1 - Addressing awareness & understanding (University of Glasgow)
Legal requirements
Duty of Care training
Selection and audit of contractors for disposal
Encourage 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 records
Educate departments on retention of Transfer Notes. Periodic audit of departments.

29. Step 3 – Addressing Disposal (University of Glasgow)
Uplifts from each department and building
Environmental and sustainability issues a high priority. The issue of charities
Costs 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 initially
Review disposal quantities and costs after ~18 months
Tender for framework agreement for disposals

31. Case Study 2 (University of Exeter)
PROCUREMENT INFLUENCES:-
Communication
Waste Matters – Environmental Seminar
Sustainability Committees’
Appointment of Sustainability Adviser
WEEE ‘round-up’s’ (2006)
Tender clause
Contract Waste / Recycling Solution

32. OBJECTIVES (Exeter) WEEE Audit Partnering Arrangements
Reduction in Carbon Footprint / Co2 emissions
Advantages / Quick Wins
Lease / Rental IT Equipment UoP
Procurement 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 challenges
To ensure that the suppliers who deliver to the University have registered with a scheme (e.g. Valpak) - only 30% done so to date
To 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 £25k
Unauthorised / unregistered equipment
Unauthorised disposal methods (skip, charities)
Disposal costs (who? / when?)
Quantity and variety of WEEE
Details of compliance schemes geographical and space constraints

35. FAQ’s

36. FAQ’s (2)
level.

37. FAQ (3)

38. Further Information

41. Thank you for your attention
Any questions?
(ext 24239)
For further information please see: