You may not need to register individually in each country,
Genny
You may not need to register individually in each country, but whoever
is your importer/legal representative/entity/authorised sales
distributor in each country will need to do so. Just transferring goods
for sale from a non-EU Office to a local EU Branch, or between different
EU branches does not "put the product on the market." Certainly for
business WEEE (ie not household electrical goods, domestic
appliances,TVs etc) its the final transfer of ownership which generates
the WEEE responsibility only in the EU state where that product goes to
the end-user. The section of your company, or your appointed
distributor, concerned with that final transfer, is where the
responsibilty lies and thus not necessarily directly with the parent
organisation.
The entire final product needs to be WEEE marked on the chassis only
along with a datemark, if not using the underlined symbol (as of last
Saturday 13th August!) - individual components/cards/sub-assys which
have no separate function do not require the marking.
The administration is complex and I would recommend using a compliance
scheme to adminster the details if you are small organisation, rather
than trying to tackle this alone. As examples of schemes available, try
looking at < http://www.repic.co.uk > or <
http://www.b2bcompliance.org.uk/ > , or < http://www.erp-recycling.org/
>
Nigel Burtt
Production Engineering Manager
Dolby Labs - European HQ
Email: [log in to unmask]
Tel: +44 (0)1793 842132 [direct line with voicemail]
Fax: +44 (0)1793 842101
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Genny Gibbard
Sent: Thursday, August 18, 2005 6:48 PM
To: [log in to unmask]
Subject: [LF] WEEE symbol specifics
We are so far behind the 8-ball with WEEE it is a little overwhelming.
We are just starting to figure out how we need to register in each
country. I did a search on the forum, and saw a question from someone
regarding whether there is a list somewhere of who to contact in each
country to register, and there was no really good response. Just
wondering if anyone has an update on that, as well as the easiest way to
get English forms out of many of the countries.
Secondly, the label must be "Visible, legible, durable".
If one has a modular type system, with cards which can be swapped out, I
am assuming one should put a label on each module. Can I put it on a
part that would only be visible once the card slides out of the chassis?
I was also planning to put one on the chassis itself.
Is anyone else getting the impression that WEEE is largely an
administration challenge, with technical aspects only a very minor part
of it?
Registration, reporting, determining costs, fees, volume of sales etc.
RoHS compliance is the technically challenging one.
Genny Gibbard
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