Group,
I read that the RoHS requirements were changing a bit and that the Technical Adaptation Committee for WEEE and RoHS Directives have published unofficial notes.
Has anyone seen an official copy of the TAC WEEE unofficial notes?
Thanks,
Jeff Collins
Nic Bowker <[log in to unmask]> wrote:
Those were the kind of answers I had in my head - I suppose should have put down that I was talking about Producer direct selling to end user between EU states, as that's the bit that's doing my head in!!
Nic Bowker
Technical Resources Adviser
PLASA Ltd.
38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
Tel: +44 (0)1323 410335 : Fax: +44 (0)1323 646905
Email: [log in to unmask] : Website: www.plasa.org
When you're looking for Industry Expertise, make sure you choose a PLASA Member.
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 19 July 2005 10:01
To: [log in to unmask]
Subject: Re: [LF] WEEE question: Products selling to EM and not end user
directly???
Well that is not quite the whole picture as I understand - if you are a
UK manufacturer and you sell through importers or distributors into
other EU states then your importers are the "producers" and are liable
for obligated product.
If you are a UK manufacturer and have a presence (office) in another EU
state who handle your sales in that state then ultimately you will be
liable to register in that EU state.
If you are outside the EU and sell into the EU through
distributors/importers then they are the "producers" and thus liable.
If you are outside the EU and sell direct by mail order/internet into EU
states then no one as yet has come up with an answer - my guess is the
consumer will become responsible but as such items will be small (MP3
players etc. rather than fridges, TV's etc) Joe consumer will just throw
them out with the trash which won't be policed and so will go into
landfill. (But will obviously be a small % of the items really targeted
by WEEE.)
When the UK legislation is published, then maybe some of this will be
clarified :)
Regards,
Chris
____________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Nic Bowker
Sent: 19 July 2005 09:40
To: [log in to unmask]
Subject: Re: [LF] WEEE question: Products selling to EM and not end user
directly???
Which leads nicely onto a question I had and that I thought I had the
answer to until I talked to the DTI....
The comment about "registering with each and every country" - I had
presumed that If you were in the EU and sold to other EU countries you
had to register with each EU country to which you sold, otherwise how
would they work out your WEEE obligation.
However, according to the man at the DTI and at one of the compliance
schemes, this is not the case. If in the EU, when you register in your
"home" country you simply tell them of all the countries you sell into.
Quite how this works for "distance sellers" (i.e. outside the EU to
start with) I don't know. Nor do I understand if you haven't registered
(unless it's all being done by some giant central computer....Where are
you HAL?!) how they work out your WEEE Obligation.
Anyone care to comment?
Nic Bowker
Technical Resources Adviser
PLASA Ltd.
38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
Tel: +44 (0)1323 410335 : Fax: +44 (0)1323 646905
Email: [log in to unmask] : Website: www.plasa.org
When you're looking for Industry Expertise, make sure you choose a PLASA
Member.
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 19 July 2005 08:50
To: [log in to unmask]
Subject: Re: [LF] WEEE question: Products selling to EM and not end user
directly???
Ken,
It sounds very much like you are not the ones "placing the equipment on
the market". The company you are selling to are the ones placing on the
market and are therefore the importers/distributors and so become "the
producer". The obligation is therefore theirs.
Just my opinion.
Regards,
Chris
____________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kanaiyalal Patel
Sent: 19 July 2005 01:51
To: [log in to unmask]
Subject: [LF] WEEE question: Products selling to EM and not end user
directly???
All,
If we sell EEE products to EM (Equipment Manufacturer), do we still has
to register with each country and provide all sorts of sales and other
data? Our product is for Networking and Telecommunication companies and
we do not sell directly to the end users. If they need replacement part
they have to buy it from EM.
Any comments on WEEE implementation besides marking of the products.
Re,
Ken Patel
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