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May 2020 Newsletter

Newsletter: May 2020

The latest news regarding WEEE, e-waste, battery and packaging compliance

Demonstration, Research, and Development Units: when are they considered WEEE in the European Union?


A question often asked is “when are demonstration units or research electrical devices exempted from being categorized as WEEE in the EU?”. The EU WEEE Directive 2012/19/EU in Article 2(4)(f) states that an exemption applies to:

equipment specifically designed solely for the purposes of research and development that is only made available on a business-to-business basis;

The intention of this exemption is to not create burdens with electronic waste laws that would stifle innovation, research, and development.

The European Commission’s guidance in the Frequently Asked Question (FAQ) reference defines the circumstances when the exemption does not apply:

Standard equipment, such as monitoring devices or instruments for chemical analysis and other laboratory equipment, that can be used both for R&D applications and in commercial or other applications does not benefit from this exclusion. Neither does the exclusion apply to equipment designed and placed on the market to test, validate or monitor R&D equipment and/or prototypes

It is important to note that whilst the FAQ is not a legally binding document, the guidance carries significant weight when determining applicability of the rules.

This means demonstration units are not exempted and are considered WEEE in the European Union.  The key defining feature for exemption is products that are still in a conceptual stage, such as a product in development, still being designed, and not yet in production. Finished products placed on the market for evaluation by potential clients are WEEE and as such carry the associated compliance obligations.  If you would like to check to see if your products are exempted or not, please contact us at Accerio to discuss an obligation assessment.

Financial Guarantee In Europe Overview


In some EU countries WEEE Producers are required to have a Financial Guarantee in place. If it is required in an EU country where a registration is in place, then you should already be compliant with this requirement and Accerio will have put it in place for you.

What is a financial guarantee, and why is this requirement in place?
The intention of the WEEE directive 2012/19/EU is that those who place products on the European market (i.e. producers) should finance the costs of the end of life management of these products. This includes a provision that in the event that the company ceases to exist, the costs of managing their products does not fall on society or on other producers.

The financial guarantee also represents one of the rules governing how waste can be shipped into or out of a country. Producers must ensure that there is enough money available for the Environment Agencies to deal with the waste if the shipment is not completed, including the cost of returning the exported waste.

The costs are calculated according to the amount of EEE placed on the market, taking into consideration that will one day it will become waste (i.e. WEEE).

The producer can choose to fulfil this obligation individually or in many EU countries can satisfy the requirements by joining a collective scheme. If complying individually, in principal there are two major approaches for the individual guarantee:

  • bank deposit/blocked account (in cash)
  • bank guarantee (on a contractual basis with a monthly interest to be paid by the notifier)

EU Member States agree that the financial guarantee itself depends on the hazardousness of the waste, quantity, transportation route, etc., and it is strictly calculated according to the national/regional formulas. The totals can differ because the disposal costs and quantities for the waste vary greatly. In some regions, as a rule, companies apply for partial guarantees, covering only a subset of transports at a time.

For many companies, the financial guarantee will never be used, as long as the company remains functioning; but it is important that a contingency exists in case it is ever needed.

Africa: Electronic Waste Extended Producer Obligations Overview


In Africa market failures are generating pressure for an increase in implementation of WEEE/E-Waste laws, with Extended Producer Responsibility (EPR) programs, and associated compliance requirements.

Currently only Ghana, Nigeria, Rwanda, and South Africa have legislation in force that is binding, with varying degrees of operational capacity. The definition of obligated producers and products covered by these laws varies, but most include foreign manufacturers in the definition of obligated Producers. Kenya has WEEE legislation in place and Cameroon has proposed legislation in progress, with both still to implement fully operational EPR programs.

Africa has rapidly growing electronic waste streams from both imported E-waste and second-hand electronics, as well as local generation. The UN Global E-waste Monitor estimates that less than 1% of all the E-Waste in Africa is currently collected, with the growth in electronic waste generated expected to reach a net volume of over 50 million tonnes in total by 2020.

The capacity for growth in this region is manifest, and along with insufficient municipal funding to address the problem, there is an increased interest in development of EPR programs. Given the need for solutions, it is expected that other countries in Africa will follow suit with their own electronic waste laws including EPR programs.

If you are selling electronics products into Africa and wish to understand your obligations, please contact us at Accerio to discuss a compliance obligation assessment.

May 2020 Newsletter Read More »

March 2020 Newsletter

Newsletter: March 2020

The latest news regarding WEEE, e-waste, battery and packaging compliance

Compliance Is Going Digital

The use of Electronic IDs is becoming mainstream in the EU for WEEE, batteries and packaging compliance and is increasingly required to perform required compliance activities including registration and reporting. The European Union Directive 910/2014, eIDAS (Electronic Identification, Authentication and Trust Services), directs that from September 2018 all organizations using digital services must recognize electronic identification from all EU member states. At Accerio we are seeing this roll out as more and more countries are adopting this system, and countries outside of Europe increasingly have similar systems and requirements.

The use of E-ID’s provides safer and more efficient electronic interaction between businesses, citizens and public authorities, and these digital transactions have the same legal standing as paper transactions. The main purpose of the regulation is to strengthen the cross-border collaboration and to reduce the time and effort when it comes to some administrative tasks, and to provide transparency and inter-operability to support the new Digital Single Market.

Producers registered for WEEE, batteries or packaging in the European Union may need to apply for an E-ID in the EU member state where they sell from, and implement trust services programs in their business system, in order to comply with EPR compliance obligations. Some EU countries have had electronic ID systems in place for a few years, but it is a more recent development to have these IDs recognized in EU Member States other than the one where they were issued. Some countries already have their systems up and running and others are coming online now with partial implementation and limited access for a specific short list of countries, which is expected to expand.
As E-ID’s become more common Accerio will reach out as related changes occur that affect your registrations.

Singapore’s Electronic Waste EPR Program Goes Live

Singapore has launched their new electronic waste Extended Producer Responsibility program for electronic waste and packaging. The program is being rolled out in phases with phase 1 now in operation (active from January 1, 2020) with the establishment of a national Producer register requiring obligated Producers to register in order to sell electronic products covered according to the Resource Sustainability Act 2019.

Later this year phase 2 will come into effect and when the new packaging obligations apply. The remaining provisions of the program will be established by July 2021.

Producer requirements have some similarities to the EU WEEE responsibilities including:

  • Registration for obligated producers
  • Reporting weights and units sold
  • Join a Producer Responsibility Scheme (for specific producers)
  • Facilitate free takeback
  • Takeback reporting
  • Public Education

Unique features of the system influence obligations, which can include minimum thresholds and product scope, and individuals would need to be assessed to determine compliance responsibilities. Non-compliance carries significant financial penalties, including potential conviction of an offence under the Singaporean act and imprisonment, and the Act includes a provision for the right for authorized officers to conduct surprise inspections.

If you’d like to know more and understand your obligations in Singapore, please reach out to us on and we’d be happy to conduct an assessment to determine if responsibilities apply.

EU Waste Regulations Amendments

The EU is currently reviewing the Waste Framework Directive, as part of the new Circular Economy Package. This will have an impact on all Member States and will create changes for WEEE, battery and packaging producers.

The outcome is projected to be a system that is in greater harmony with the tenets of a circular economy. The new model is expected to promote a growth in secondary markets for used but still functioning EEE, with an increased focus on making better use of EEE to reduce the amount of electronic waste and create products that are less polluting than previous versions.

The drivers of change for Member states will be:

  • Member States must facilitate:
    • Innovation of production
    • Models to reduce hazardous substances in materials and production
    • Encourage increased lifespan of products
    • Promote re-use and use of recycled products
    • Promote recycling of materials.
  • Minimum operating requirements for extended producer responsibility schemes.
  • Member States’ obligation to set up separate collection for paper, metal, plastic, and glass waste, and better measures for re-use of waste after its collection, and recycling.

The anticipated impacts from these programs on Producers are expected to include:

  • Product design changes to improve life-span, repairability, recyclability and re-useability of products and packaging, which may include requirements for example such as making repair manuals readily available
  • Increased standards for chemical/pollutant content of product material composition, with a stronger connection between waste compliance and chemical compliance (REACH and RoHS legislation)
  • A possible increase in reporting for adherence to new measures with e.g. declaration statements, quality control, self-monitoring, and accreditation requirements etc.

As the specifics of the program become available Accerio will keep you informed.

March 2020 Newsletter Read More »

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