German Scope Updates
At the beginning of the year the German WEEE authority announced that “passive” devices (devices that only transmit currents or signals) will be in scope as of the 1st of May and thus need to be registered This development brings Germany into line with what is already common practice in many other European countries.
Here are some examples of passive devices:
Passive devices are to be categorized in either category 4 (large devices), category 5 (small devices) or category 6 (small ICT devices).
Passive devices vs. components
To differentiate between Passive Devices and Components, the new rule is of relevance to end-equipment designed for operation with a maximum alternating voltage (AC) of 1,000 volts or a maximum direct voltage (DC) of 1,500 volts. Components, such as cable by the metre, ferrules or ring cable lugs, remain out of scope.
If you are a manufacturer of passive devices, you should check the following:
Do you already have a registration for the corresponding device type and brand?
|Yes, I have the required registrations||No, I am not registered in the required categories|
|From May onwards, we can simply add the quantities of your passive devices in the corresponding device type to your regular reporting.||Please get in touch with us so that we can arrange for a respective registration. As the approval procedure by the respective Authority can take up to 12 weeks it would be preferable to apply for registration in February.|
2018 in Review
2018 was a big year in the WEEE/e-waste, batteries and packaging compliance world, with some significant changes and developments.
- The European Union underwent a significant change with the advent of new reporting categories, called Open Scope, to expand and facilitate improvement of recycling and reporting of electronic waste. The previous system used 10 categories and the new system has 6 categories for reporting and more products are now expected to be reported.
- The German reporting structure underwent some big changes with the new packaging law and associated authority launching, plus bringing new products into scope (see passive instruments article for reference).
- Poland launched the new BDO environment authority superseding the previous GIOS organization and expressed intent to increase enforcement activities.
- Portugal experienced significant changes in the reporting systems and procedures. Additionally the Portuguese Environmental Agency became more active in enforcing correct implementation of Authorized Representative requirements and notifying distance sellers of packaging obligations.
- 2018 saw an increase in compliance enforcement activities across the EU, especially in Ireland and Germany, with a greater and more aggressive focus on the full range of compliance requirements that occur after registration.
- The advent of the European WEEE Enforcement Network (EWEN) which co-ordinates environmental authorities across the EU started in late 2017 and stepped up their strategy and efforts to crack down on free-riders in 2018, especially the growing area of online sales of electronics.
The changes in 2018 demonstrate that ongoing monitoring of the ever changing EU WEEE, batteries and packaging compliance landscape is imperative to ensuring full and correct compliance with stricter enforcement expected in 2019, and Accerio as your compliance partner is here to ensure you are covered.
E-Waste Compliance in Canada
In Canada, E-Waste laws are in place in all 10 provinces and in 2 out of 3 territories (with Nunavut the exception). Provincial and territorial governments regulate Extended Producer Responsibility programs through local law. Some governments began targeting e-waste management about 20 years ago, while others came into effect as recently as 2017.
Canada requires producers to participate in an approved stewardship program and to pay the appropriate environmental handling fee (EHF) for each regulated product sold into a province or territory. While the country continues to move toward standardization of product categories, each province and territory maintains their own laws and individual list of products that are considered to be in scope of e-waste.
EPR laws focus e-waste stewardship responsibility on a variety of players, including manufacturers, brand owners, importers and retailers. It can be difficult for companies that sell into Canada to know what their EPR requirements are, whether the products they sell are ‘regulated’ and into which province or territory they are considered to be regulated. In addition, regulated product lists continue to evolve, making it necessary to review obligation status on an ongoing basis. There are also battery and packaging laws in place which look at producer responsibility differently from e-waste, which adds to the complexity of meeting compliance requirements.
If your products are sold into Canada and you would like to understand whether you have any obligations as a steward, you can simply contact Accerio for an obligation assessment. Our country experts keep track of this ever changing landscape and are available to help simplify compliance in Canada and help you fulfill your legal obligations.