Reuse Network responds to EA guidance on WEEE definitions

The Environment Agency has released new guidance regarding the distinction between EEE and WEEE –When electrical and electronic equipment (EEE) becomes waste (WEEE)

The guidance is to help the following groups decide when they are dealing with EEE and when they are dealing with WEEE:

• approved authorised treatment facilities (AAFTs)
• designated collection facilities
• producer compliance schemes
• organisations involved in preparing used EEE for reuse
• organisations with EEE they no longer need
• waste carriers

Definition of EEE and WEEE

EEE means equipment which is dependent on electric currents or electromagnetic fields to work properly.

EEE also means equipment for the generation, transfer and measurement of such currents and fields, designed for use with a voltage rating not exceeding:

• 1,000 volts for alternating current
• 1,500 volts for direct current

WEEE means electrical or electronic equipment which is ‘waste’ within the meaning of Article 3(1) of the Waste Framework Directive as read with Articles 5 (by-products) and 6 (end of waste) of that Directive. Therefore, any EEE which the holder discards, intends to discard, or is required to discard, is ‘waste’. This includes all components, subassemblies and consumables which are part of the item at the time it is discarded.

Craig Anderson, CEO of Reuse Network shares his views on the new WEEE guidance

It is important for all Reuse Network members who handle, process, reuse and repair electrical and electronic equipment (EEE and WEEE) to read through and get to grips with the implications of this guidance which will be a foundation for Environment Agencies to regulate the WEEE system and also review those that reuse EEE that has been donated.

In truth there is little difference to how the sector has worked since 2007 when WEEE was first transposed – so from a Reuse Network perspective it is reuse business as usual. However, there are two issues to be aware of:

1. The first is the expectation implied that the original owner passing on or donating the item is aware that it only needs a “minor” repair to be usable again. How can we expect the first owner to have the expertise to know that only minor repair is required? It may look ok, but no-one knows the extent of repair required until a trained technician opens it up – and that includes the driver collecting the item.
2. Any EEE you deem irreparable but wish to salvage parts for further reuse in other similar products – the parts become WEEE. If during repair or refurbishment the holder decides an item of EEE is not suitable for its current use and dismantles it into its different components, then the EEE has been discarded and so becomes WEEE. The dismantled components that are removed from an item of WEEE are waste. To reuse these components, for example to refurbish another item of EEE, the components must meet the end of waste requirements.

To us at Reuse Network we say this is unworkable and will impact not just Reusers, but all those appliance and tech repairers in the private sector.

Just because the Reuse Network membership wishes to comply with such regulations, does not mean we should be at a disadvantage to other EEE product repair sectors.

If salvaged parts from electrical equipment are deemed waste, then so should any salvaged part from any product therefore be deemed ‘waste’ – including, big-brand forecourts, OEM refurbishment operators, salvage yards and IT asset companies to name but a few.

“Reuse is not about waste, it’s about the consumer (in our case the low-income consumer), and we desperately need to deflect waste policy interventions that stifle our reuse and repair sector to ensure quality reused and second-hand goods are supplied to people in crisis in the UK.”

Want to work with us to tackle e-waste?

If you’re a commercial organisation looking for ways to extend the life of your electrical products, or maybe you’re looking for ways to incorporate reuse into your ESG goals, get in touch with us here at Reuse Network to chat. Find out more about what we do. 

Email Hannah Jordan, commercial manager: hannah.jordan@reuse-network.org.uk, or call 0800 085 8339