WEEE directive: What EU electronics importers must know

by Fredrik Gronkvist

Unlike RoHS, which restricts usage of heavy metals in electronics, the WEEE (Waste Electrical and Electronic Equipment) directive has several elements, each having an on electronics importers in the EU. Among there are recycling contribution schemes, dismantling design requirements, and labelling requirements. We will get back to those in a bit, but first you might want to know which product categories are within the scope of regulation.

As hinted by the table above, if your business is importing electronics within the EU, the WEEE directive is having an impact on your business. However, note that the table above is not listing all categories, or products, within its scope of regulations. For a more comprehensive list, click here.

Eco-design and product dismantling requirements

The design for dismantling (also known as design for recycling, or design for disassembly) includes the practices to optimize the way how a product will be treated at end of life, and to optimize the separation of components and materials for their recovery (repair, recycling, energy recovery). The design for dismantling applies equally to a product to be disassembled as for products intended to undergo a grinding step.

Considerations are particularly related to choice and combination of different materials that compose a product but also to the assembly and mechanical connections between components and subassemblies of the product. Source

The WEEE directive requires products to be designed in a way that simplifies the dismantling, for either recycling or further usage. As WEEE covers such a large number of products, there are, at least as of today, no technical requirements applicable to each product. As such, it’s up to the "producer" (i.e., the importing company, when the supplier is located outside of the EU) to ensure that the product is designed in compliance. For example, this may include the following:

1. Removable batteries
2. Easy separation of electrical components
3. Easy separation of different materials (e.g. metal alloys and plastic)

For startups and small businesses, lacking the technical capability, or budget, to develop OEM products, or at least modify an existing factory design, this poses a major challenge. My best advice for this group of buyers is to make a compliance assessment based on factory samples. However, most Chinese electronics manufacturers are, for natural reasons, not concerned with ensuring said design compliance. As always, Western buyers must strictly limit their supplier selection to those with an existing compliance track record.

WEEE labelling requirements

Take a good look at your phone or laptop charger. The WEEE symbol, as seen on the right, indicates separate collection and recycling. The WEEE mark is mandatory for most electronics, imported and sold within the EU.

The WEEE mark must be clearly visible on the product itself, and its packaging, unless this is deemed to be impractical. Also note that the WEEE mark is not a replacement for a CE mark, which indicates compliance with all other, applicable, EN directives.

When buying from China, never leave the product labelling in the hands of the manufacturers. Provide all graphics files, including labels, directly to the supplier, rather than making the assumption that they'll 'get it right'. After all, your business is taking the heat if the products turn out to be improperly labelled

WEEE registrations and yearly contributions

In addition to dismantling design and labelling requirements, the WEEE directive also sets yearly ‘recycling contribution’ requirements, for importers and distributors. In practice, this means that your company must pay its fair share to finance the recycling network, on a yearly basis. These recycling fees are based on yearly sales volume, usually counted in tons.

There are certain limitations though. For example, in the United Kingdom, the yearly contribution only applies to companies with yearly sales volumes equivalent of at least 5 tonnes:
A small producer must join a PCS (producer compliance scheme) within 28 days of placing more than 5 tonnes of EEE on the market in any compliance period.

What I must also mention at this point, is that the WEEE Directive is implemented individually by each EU member state, according to its own ‘national producer compliance scheme’. As such, the implementation may differ, to a varying degree, between different EU member states.

Further reading

• UK Government Guidance Notes: WEEE Regulations 2013
• Kingfisher Sourcing: Basic Requirements for the WEEE Directive
• Eco Design Guide of WEEE Compliance Schemes

Fredrik Grönkvist is the co-founder of ScandinAsian Enterprise in Shanghai. Since 2010, he and his team have helped hundreds of companies worldwide, primarily in the EU and US, to develop and manufacture products in China. He is also the main contributor on www.chinaimportal.com, a leading knowledge base for small- to medium-sized enterprises importing from Asia. For further questions, you can contact him on www.chinaimportal.com/contact-us/