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UK WEEE Open Scope - Are you ready for 2019?

UK WEEE Open Scope - Are you ready for 2019?

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by Harry Wild, November 2018
Harry Wild is a Consultant in thinkstep's Recycling Compliance practice and graduated from the University of Nottingham with an MSc (Hons) in Chemistry.
From January 2019, all EEE products are in scope of the UK WEEE regulations unless specifically excluded.  The UK Environment Agency has recently published a guidance document finalising the equipment covered by the regulations. 

Companies are having to re-assess their products in preparation for 2019 UK WEEE reporting 

The implementation of 'Open Scope' as part of the EU WEEE Recast Directive (2012/19/EU) means many companies may now need to report on additional products to remain compliant with the law. Your company could face fines for incorrectly reporting equipment. 

The UK is sticking to the existing 14 WEEE categories but lots of additional products, that were previously out of scope, will now fall into these categories. 
 
Excluded products
The following products are excluded from the scope of EEE:
  • Equipment designed to be sent into space 
  • Large-scale stationary industrial tools
  • Large-scale fixed installations
  • Transport for persons or goods, excluding electric 2 wheeled vehicles which are not type-approved
  • Off-road mobile machinery only for professional use
  • Equipment designed only for research and development use and only available via business to business (B2B)
  • Implantable medical devices
  • Medical devices that are expected to be infective at end-of-life
 
Accessories 
The UK guidance document confirms that non-electrical accessories are no longer in scope. Previously, items such as; a protective case supplied with a power tool or, a plastic jug sold with an iron, had to be reported as part of the total EEE product weight. This is no longer required. 
 
It is important to note that if the item is necessary for normal operation of the product. For example; a microwave oven glass plate or fridge shelf, it must still be reported and included as part of the EEE weight.
 
Large-scale fixed installation components
Large-scale fixed installations are excluded from the scope. However, any equipment that is not specifically designed for and is not integral to the installation is still considered an in scope EEE product, if it can carry out its basic function in its own right. For example, display screens or lighting equipment will be in scope. 
 
Household luminaires
Household (B2C) luminaires will be in scope of the UK regulations from January 2019. Previously only professional-use (B2B) lighting was in scope.  

This will affect a large number of companies, as it means that items such as; decorative lighting chains, table, ceiling, wall, garden and other types of lighting are now all considered in scope and will need to be reported from 2019. 

How do I ensure my company is reporting correctly?

You should carefully consider all of the products that you are placing on the market in the UK to check that you will be reporting correctly in 2019. We can provide assistance if you are unsure whether your products fall in or out of scope.

All EU member states are required to implement open scope but each country has their own interpretation and timeline for introducing these changes. For guidance and advice on how to deal with all of these changes and ensure you are reporting correctly across the UK and EU, please contact us.

For more information on the implementation of open scope across the EU, you can watch and download slides from our recent webinar.