by Sam Smith, August 1st, 2017
Sam is an EC4P Compliance Consultant helping companies identify their legal exposure to WEEE, Batteries and Packaging legislation and providing cost-effective and legally-robust recommendations for compliance.
EU Member States are currently in a ‘transitional period’ in regards to the product scope of the WEEE Recast Directive and until the 15 August 2018, the current scope of 10 EEE categories will remain in place.
From 15 August 2018, the WEEE Recast Directive requires a new product scope to be introduced. As well as the concept of the ‘open scope’, the new product scope will include:
The six new categories which will apply from 15 August 2018 are:
However, Bulgaria, Hungary, Poland, Slovenia and Sweden will introduce the six new categories on 01/01/2018, earlier than outlined in Article 2 of the WEEE Recast Directive. France and the UK on the other hand will delay implementation until 01/01/2019. Some countries, Austria as an example, have already adopted the new categories.
The practical implementation of the change is still largely unknown and for the UK, with 14 current categories and on the verge of leaving the EU, the future is even more uncertain. DEFRA is currently assessing various options to streamline the process, such as amending the UK regulations to retain the existing 14 categories but create protocols to report to the EU under the six new categories. Nevertheless, as the categories become wider, and since recycling costs are based on the producer’s market share of the category, DEFRA have suggested that some recycling fees may increase. For example, in the new category 4, producers of large household appliances may end up subsiding the cost of recycling large complex medical devices and vice versa.
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