How do I arrange for the return of discarded electronics?

What you must concretely do

What is expected of you

The WEEE Directive (Directive 2012/19/EU) regulates how waste electrical and electronic equipment is collected, processed and accounted for. The directive is directed at producers — and this concept is broad: an importer or a company that places equipment under its own brand on the market also falls within this scope. What this means in practice breaks down into a number of separate obligations.

Registration as a producer

Anyone who places electrical or electronic equipment on the market is considered a producer under the directive, regardless of whether the equipment itself was manufactured. For a company with 10 to 100 employees, this means that registration with the national authority that maintains the WEEE register is a first step before equipment is sold — not something that is rectified afterwards. This is usually one of the first points an inspector asks about; see also what an inspector asks about during an inspection on electronics.

Financing of collection and processing

The directive places the financial responsibility for collecting and processing waste equipment on the producer. In practice, this usually takes place via a collective scheme to which contributions are made, rather than each company setting up its own collection network. The contribution is linked to the quantity and category of equipment that is sold, and records of this must correspond to what has actually been placed on the market.

Take-back at distributors

For distributors and sales outlets, the directive provides for a take-back obligation: upon sale of new equipment, old equipment of a comparable type may be taken back, and for small equipment this can also be done without the purchase of a new product. For a company with a retail floor or service point, this means that there must be a physical location and a process to receive, register and channel returned equipment to the correct processor.

Information to users

Producers and distributors are expected to inform users about the way in which equipment can be returned, and about the symbol of the crossed-out waste bin that indicates that equipment should not be discarded as ordinary waste. In practice, this relates to labelling, packaging and communication at sales outlets, and it is not a one-off action: new product lines bring the same information obligation each time.

Reporting on quantities

Producers are expected to keep records of and report how much equipment has been placed on the market and, through the supply chain, how much of it is collected and processed. For a mid-sized company, this means that internal sales records must be traceable to the categories distinguished by the directive, so that reporting does not become a reconstruction exercise each year.

Where things go wrong in practice

A number of recurring situations stand out among companies dealing with WEEE obligations.

Registration lags behind sales. A company begins selling a new product line — for example via a webshop — before registration as a producer is completed. This often only becomes apparent during an inspection, not at the point of sale itself.

The take-back obligation is not implemented on the retail floor. Staff are unaware that small equipment can be taken back without the purchase of a new product, or there is no clear location where returned equipment is collected. This leads to inconsistent treatment of customers who wish to return equipment.

Contributions to the collective scheme do not match actual sales. Particularly during growth or when adding new product categories, the notification to the collective scheme is not updated, so that records fall behind what is actually being sold.

The symbol and information obligation fade into the background with private label. When a company has equipment manufactured under its own brand, the obligation to include the WEEE symbol and take-back information is sometimes left to the manufacturer without verifying that this is actually done.

Documentation is not kept centrally. Registration certificates, contribution statements and correspondence with the collective system are scattered across different departments or individuals, which means that during an inspection time is lost gathering documents that do exist but are not kept in one place.

What you can document

A number of documents and agreements can be used to make WEEE obligations demonstrable and manageable:

• The registration certificate as a producer, including the date on which the registration became effective in relation to the first sale.
• An overview of the product categories being sold, linked to the classification that the collective system uses for the contribution.
• An internal process for the take-back obligation in the retail store or service point: who takes back the equipment, where is it stored, and who arranges for transport to the processor.
• Instructional materials for staff on the take-back obligation and the WEEE symbol, including a time when this is repeated for new employees or new product lines.
• Proof of contribution to the collective system per period, compared against your own sales figures.
• Correspondence with suppliers or manufacturers about who assumes the WEEE obligations, especially in the case of private label or import.

These points overlap with the broader approach to the digital product passport: anyone who is now drawing up a plan for the implementation of the product passport in the organisationcan logically incorporate the WEEE administration into it, because both subjects require traceability of what is placed on the market. For companies uncertain whether their equipment will fall under the product passport obligations, the question whether the digital product passport applies to their own electronics is a good starting point, and for those who do not yet know where to begin there is an overview of what can already be done while the rules are not yet final.