November 2019 Newsletter

Newsletter: November 2019

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

The Circular Economy:
Subscribe to a Sustainable Environment

The European Union recently presented the Circular Economy Package, which includes waste directives adopted by the European Parliament and the EU Council amending, among others The Waste Framework Directive (2008/98/EC).
The Circular Economy conceives a system where energy sources are renewable, a reduction in waste production, and waste viewed as a resource instead of a burden for society.

The ‘Waste Hyperarchy’ addresses the entire product cycle of production, consumption, waste management and market for secondary materials to achieve a more efficient use of primary and secondary resources.

Potential impacts on Producers of WEEE, Batteries, and Packaging Producers selling into the European Union include:

  • Economic benefits for Producers of products with more efficient and better ecological designs
  • Greater Extended Producer Responsibility costs for products with poorer ecological and lower efficiency performance of products
  • Increased regulation of:
    → Eco – design criteria
    → Product design
    → Use of hazardous materials
    → Product markings
    → Data collection methodology
    → Easier trade of ‘waste’ i.e. secondary materials
  • Packaging re-design to reduce superfluous secondary packaging and reduce single use plastics, especially those associated with food and beverages, and fishing gear
  • Products designed for Re-Use, Repair, and Recyclability, including repair manuals to be made available
  • Increased standards for chemical/pollutant content of product material composition
  • Requirement to increase of life-span of products

Accerio will keep you informed of practical impacts as they unfold.

Shipping electrical products for repair or re-sale: is it EEE, or is it WEEE?

mobile-phone-2510529_1920

When transporting used EEE it is important to know what is required to avoid falling afoul of the European Union’s Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste (WSR). This is an important consideration when shipping the following:

  • End-Of-Lease electronic products
  • Used electrical products
  • Faulty or malfunctioning products
  • Electronic goods destined for repair reuse and re-sale

To qualify as EEE the goods must meet certain criteria. The way in which the ‘holder’ of the electrical products treats a product can be interpreted as an indicator of whether or not the goods are truly EEE or are waste. Specifically considered is the evidence of intent to re-use the goods or discard them as waste; it must be demonstrated that the goods are not to be discarded or intended to be discarded. To qualify as EEE:

  • The electrical goods should still be functional for the original purpose; this must be documented with an invoice and or statement to this effect
  • The goods are to be protected from damage in transit e.g. original packaging or other packaging
  • There must be evidence of testing for functionality
  • Malfunctioning electronic products that are intended for repair and re-use must demonstrate the potential for re-useability, that the re-use is certain, testing and or repairs necessary for the item to be reusable have been carried out, or will be carried out by specialized technicians on receipt of the shipment. Documentation of this is required
  • There must be some certainty of the re-use of the products
  • There cannot be intention to discard the products after the transportation, that they cannot be regarded as a burden for the purchaser
  • Redundant stock lines in unopened original packaging will be regarded as EEE
  • Documentation of any or all of the above must accompany the goods during transit, including a declaration the goods are not waste

A cautionary tale is the recent case in July 2019 of Openbaar Ministerie v Tronex BV, where a company was preparing to ship from The Netherlands to Tanzania a consignment of electric appliances consisting of a mix of warranty returns, redundant/old stock, and non-functioning appliances that were declared as to be repaired for re-sale.  The European Court of Justice handed down the ruling against Tronex BV as well as a hefty fine, because the shipment contained electrical items had not been packaged to protect some of the goods that were intended for repair, and there was no documentation about the repairs.

For Specifics on documentation required for shipping EEE and WEEE and further details please refer to the Shipment of WEEE Guidance document in the links below, which includes the requirements from Annex VI of the WEEE Directive 2012/19/EU.

  1. Shipment of WEEE Guidance document
  2. WEEE Directive Annex VI; Minimum Requirements for Shipments
  3. Openbaar Ministerie v Tronex BV
  4. OPINION OF ADVOCATE GENERAL KOKOTT delivered on 28 February 20191 Case C-624/17 Openbaar Ministerie v Tronex BV

EU Ecodesign Measures - New Regulations in Force

elektrik-3536769_1920

On October 1st 2019, the EU Commission adopted 10 ecodesign requirements amending Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009. The objective is to reduce Europe’s energy bill through energy savings and to reduce greenhouse gas emissions, the main factor in climate change. These measures apply to the following products placed on the Union market, independently of where they are manufactured:

  • Refrigerators
  • Washing machines
  • Dishwashers
  • Electronic displays (including televisions)
  • Light sources and separate control gears
  • External power suppliers
  • Electric motors
  • Refrigerators with a direct sales function (e.g. fridges in supermarkets, vending machines for cold drinks)
  • Power transformers
  • Welding equipment

While refrigerators and welding equipment are for the first time in the spotlights, the other eight ecodesigns are already known in EU, being part of the 2009 legal framework.

The ecodesign measures primarily focus on the reparability and recyclability of the products, with a revision of the existing provisions for durability of lighting systems, water consumption for dishwashers and washing machines, and the marks on the chemical products, underlining the future relationship between Waste and Chemicals regulations.
With the energy labelling regulation, which complements the ecodesign specifications with mandatory labelling requirements, the Commission project targets:

  • The delivery of 167 TWh of final energy savings per year by 2030;
  • The reduction of more than 46 million tonnes of CO2 in the atmosphere;
  • European households save an average of 150 EUR per year.

The ecodesign Working Plan 2016-2019 is part of an ambitious project which aims to influence what happens during the use and end-of-life phases of certain products, not only in terms of energy consumption, but also in terms of waste management.

Year End Reporting: It is nearly that time again...

time-481444_1920

The end of 2019 is approaching fast, and with it the end of year WEEE, Batteries, and Packaging reporting requirements. All Producers selling into the EU will be required to report, which makes for tight deadlines at a busy time of the year.

As a reminder, here are a few tips to make the process as streamlined as possible; please let us know here at Accerio if:

  • There have been any product changes, please send us SKU numbers, weights and technical specifications.
  • There are new reporting staff and or change of email addresses, please update our information so we can be sure to be in communication with the right people.
  • There has been any takeback or recycling by yourselves or any third parties, please send us the data and information.

It’s also a good idea to touch base with Authorized Signatories in your organization to remind them that some annual reports will require their signature, given it is an extra demand on them at a busy time of the year.

If you would like us to check through your data before the end of year to ensure that January is as stress free as possible, please feel free to contact your account manager.

On the Move

Accerio has outgrown the current space we occupy in the Netherlands and the time has come to relocate.

The big move is now complete, with the assistance of bicycles, ramps, stroopwafels and the local weather being nice enough to hold back snow and rain.

We now have larger premises in a great part of town east of the city centre at:

Panamalaan 8D
1019 AZ Amsterdam
The Netherlands

Please ensure you update our address in your records; our phone number will remain the same:

+31-20-716-3480

Please do stop by to say hello if you are nearby!

November 2019 Newsletter Read More »