1st Jan 2007

Producer Compliance Checklist

The WEEE Register Society Ltd is here to assist their registered producers as much as possible. For your convenience we have issued this checklist to help you along the required stages of compliance with the WEEE Regulations. Please review the checklist below carefully.

WEEE REGISTER SOCIETY COMPLIANCE CHECKLIST

1. Establish if you are considered a producer under the definition of ‘Producer’.

• Apply for registration with the WEEE Register Society Ltd.
  
  
• Pay the correct registration fee.
  
  
• The WEEE Register will issue you with a registration certificate and a unique five digit registration number.
  
  
• Display this registration number on Invoice, delivery dockets, credit notes etc…
  
  
• Automatically you will receive, by email your Username and Password from the WEEE Blackbox.
  
  
• Receive and complete WEEE Blackbox Historical Data Spreadsheet.
  
  
• Submit monthly data to WEEE Blackbox including weights and units of EEE products you placed on the Irish market.
  
  
• Re-register by 31st January 2006, and annually from that date.

2. Determine if your EEE products are classed as B2B (Business to Business) or B2C (Business to Consumer).

A. If you have established you are B2C you need to join a compliance scheme, either;

• ERP (European Recycling Platform)
• Ph/Fax: 01 4953889
• Email: ireland@erp-recycling.org
• Web: www.erp-recycling.org
  
  
• WEEE Ireland
• Ph: 01 2999320
• Email: info@weeeireland.ie
• Web: www.weeeireland.ie

• Apply and receive scheme membership.
  
• Pay monthly invoice, which is based on your monthly data submission to the WEEE Blackbox.

B. If your EEE products are B2B, you can either join a compliance scheme or self comply.
If you wish to join a compliance scheme you can join either ERP or WEEE Ireland. If this option is not open to you, you can self comply.

Requirements for B2B self compliance are;

• Collect or provide for the collection of your proportion of WEEE arising from WEEE placed onto the market prior to 13th August 2005, which is dependent on your current market share. The market share target is provided by WEEE Register Society Ireland - Black Box Function.
  
  
• Ensure that any collection point and recovery facility carrying out the treatment of WEEE complies with the technical requirements as set out in the Sixth Schedule (Article 20).
  
  
• Adhere to the obligations for the treatment requirements of WEEE (Article 21).
  
  
• Achieve specified recovery rates depending upon the category and type of the WEEE arising (Article 22) and to maintain documentary evidence of progress on these targets. Producers can obtain this documentary evidence from their waste management contractors.
  
  
• Maintain and keep records of all treatment and recovery data, including specific weights in and out of treatment facilities, for a period of at least 6 years (Article 23).
  
  
• Prepare a WEEE waste management plan* and provide it to the EPA, at least once every three years (Article 24).
  
  
• Producers are obliged to inform waste management facilities of the appropriate re-use and treatment information for the products it places on the market after August 13th 2005, including a list of dangerous substances and the location of such substances in each product (Articles 25 & 26).
  
  
• Producers are also obligated to mark their product with the appropriate marking identifying that the producer of the EEE has registered with the Registration Body in accordance with their terms and conditions (Article 27 & Ninth Schedule).
  
  
• Producers must not use design features or production processes that make it difficult to reuse or treat the WEEE unless such designs have overriding environmental and/or health and safety advantages (Article 40).
  
  
• Obligations under Article 41 on the Reuse of EEE.

WEEE arising from sources other than households - Business to Business (B2B) WEEE - Articles 17 & 18 a. From the 13th August 2005, each producer (or someone acting on his/her behalf) must finance the environmentally sound management of WEEE arising from B2B customers as follows:

i. For historic B2B WEEE (equipment placed on the market prior to the 13th August 2005 that is now waste), the producer is obliged to take back WEEE of a similar type and function (irrespective of brand) when a business end user is purchasing new equipment from him/her. The producer is then responsible for the collection and environmental management of the WEEE.
If the business end user is simply discarding the WEEE and not replacing it, the responsibility for ensuring the environmentally sound management of the WEEE remains with the business end user. An appropriately licensed and permitted waste management operator must be used to transport and manage the waste in both scenarios.

ii. For new WEEE (equipment placed on the market after the 13th August 2005 that will become waste), the producer must take back and manage WEEE from the business end user or make alternative financing arrangements with the business user i.e. there must be a formal agreement between both parties on how and who will finance the management of the WEEE. The WEEE must be transported and managed by appropriately licensed and permitted waste management operators.


*Note: As in B2B, i.e. - the end user is commercial, Article 24(10) regarding the display of visible environmental management costs via self-compliance do not apply.


*Note: WEEE Environmental Management Plan

• Submit 1 Hard Copy
• Signed by Senior Management
• Send to: E.P.A Headquarters