WEEE Compliance

WEEE stands for Waste from Electrical and Electronic Equipment. The first EU WEEE Directive (Directive 2002/96/EC), which took effect in February 2003, mandates the treatment, recovery and recycling of electric and electronic equipment. This Directive provided for the creation of collection methods where consumers return their WEEE free of charge. WEEE 2 (Directive 2012/19/EU) took effect on February 14, 2014.

WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance dovetails into WEEE by reducing the amount of hazardous chemicals used in electronics manufacture. RoHS regulates the hazardous substances used in the manufacture of electrical and electronic equipment (EEE), while WEEE regulates the disposal of this same equipment. All applicable products for the EU market must pass WEEE compliance and carry the "Wheelie Bin" mark. So manufacturers of EEE must not only follow RoHS compliance but also WEEE compliance for end-of-life.

Previously, WEEE only covered specific equipment. Starting August 15, 2018, the scope of the WEEE widened to include all EEE, which is classified within 6 categories instead of the existing 11 RoHS product categories. Any batteries incorporated in WEEE are also collected per the WEEE Directive. However, as per Annex VII of the WEEE Directive, after collection, batteries are to be removed (either manual, mechanical, chemical or metallurgic handling) from the product and counted towards the collection targets of the separate EU Batteries Directive. They are also subject to the recycling requirements of the Batteries Directive.

WEEE Product Categories

Category 1. Temperature Exchange Equipment (TEE) - includes all EEE equipment that use substances other than water for heating and cooling. This includes refrigerators, air-conditioning equipment, and heat pumps.

Category 2. Monitors and equipment with large screens - includes monitors, televisions, laptops, tablets, e-book readers with screens greater than 100 cm2 and whose primary focus is displaying information. So would NOT include smartphones (too small) or smart fridges with screens (primary use is cooling, not displaying information).

Category 3. Lamp bulbs - includes fluorescent, LED, HID, and LPS lamp bulbs and tubes. Does NOT include luminaires and light fixtures (which are in Categories 4 and 5).

Category 4. Large equipment - includes any EEE not included in Categories 1, 2, or 3 that has at least one external dimension (L, W, H) greater than 50 cm. This typically includes washers, dryers, electric stoves, large medical equipment, photovoltaic panels, large light fixtures, etc.

Category 5. Small equipment - includes any EEE not included in other categories with all external dimensions (L, W, H) less than 50 cm and is not IT equipment (Category 6). This typically includes vacuum cleaners, microwaves, small kitchen appliances, and consumer electronic equipment.

Category 6. Small IT/computer/communications equipment - includes any EEE not included in other categories with all external dimensions (L, W, H) less than 50 cm that is used for IT, computing, or communications. This typically includes smartphones, desktop computers, GPS equipment, printers, routers, and fax machines.

Steps to WEEE Compliance

WEEE regulations detail the collection, logistics, treatment, de-pollution, end-processing, and reuse requirements for end-of-life WEEE equipment.

1. Registration and Declaration - EEE manufacturers are required to register with the National Authority in each EU member state where they market products. The contact points for every member state are published on the europa.eu website. Each member state authorizes private organizations to register producers and to collect and prepare materials for recycling.
   A common method has been established per 2017/699 for the calculation of the weight of EEE put into the market for each EU member state along with an associated method for the calculation of the quantity of WEEE generated in each EU member state. The EU has WEEE calculation tools customized for each one of the member states. For more information, see WEEE calculation tools.
   If you manufacture a product in the EU but export 100% of it to non-EU markets, then your organization is not considered to be a manufacturer for the purposes of the WEEE Directive. However, if any portion of the production is sold within the EU, the company is a considered to be a producer under EU WEEE regulations.
2. End-user Info and Marking - EEE manufacturers must make information available to end users on the disposal of EEE: collection locations, drop-off points, take-back solutions, etc. EEE must be marked with the black-and-white crossed-out wheelie bin symbol. If the EEE is too small to display the symbol, then the symbol must be displayed in the user manual.
3. Collection and Weighing - Collection companies will receive the WEEE, log the weight of materials collected, and list the manufacturers that should receive credit.
4. Dismantling and Recovery Instructions - EEE manufacturers must create dismantling guides and recommendations for easy dismantling, de-pollution, and recovery of WEEE. Such documentation includes: 1) tools and equipment needed for dismantling; 2) procedures for disassembly; 3) instructions for removing batteries; 4) end-processing of metals; 5) recommendations for recovery and reuse, etc.
5. Take-Back Operations - EEE manufacturers should have the capacity to operate a take-back solution in a country and to provide take-back logistics. In the EU these are known as Compliance and Take Back schemes (CTBS). Take-back operators and recycling vendors shall be audited on a regular basis.
   In addition, manufactures shall finance take-back systems, treatment and recycling operations. They must also demonstrate capacity to finance such operations
6. Annual Reporting - Whether directly or through a collection company, an inventory of the all materials collected must be kept. This inventory must be submitted each year in each member state.

WEEE Exemptions

WEEE excludes the following equipment, which are similar to RoHS exemptions. Note that photovoltaic panels are NOT exempted:

• Military - equipment used for defense or national security
• Space - equipment sent into space such as satellites, telescopes, spacecraft
• Transportation - vehicles used for transport (except 2-wheeled electric vehicles)
• R&D - equipment used for professional research and development
• Non-road mobile machinery (NRMM) - agricultural, railway, waterway, construction machinery
• Large-scale fixed installations (LSFI) - electrical distribution, HVAC, robotic equipment and lines
• Large-scale stationary industrial tools (LSSIT) - CNC, milling, metal-forming, testing machines; cranes
• Active Implantable Medical Devices (AIMDs) - pacemakers, implanted defibrillators, insulin pumps
• Sub-equipment for out-of-scope equipment
• Compact flourescent light bulbs/lamps

Healthcare Equipment under HIPAA

Electrical/electronic equipment used in a healthcare organization may fall under HIPAA regulations if it stores electronic PHI (Private Health Information). In this case, the equipment must be disposed of in a specific manner to comply with the HIPAA Security Rule to prevent unauthorized access to PHI. For more information, see HIPAA Data Security.