The Environment Agency has published new guidance today that clarifies whether electrical and electronic equipment and its associated waste should be classified as either a consumer (B2C) or business-related (B2B) product.
Since confirmation in October 2014 by the Government that there would be updated guidance, ecosurety has been working with our members to contribute feedback.
In summary, if your product’s design, specification and function is for both household and non-household use, it is classified as B2C (business to consumer).
What factors are used in this assessment?
When assessing if a product is for non-household use, producers can look at the design attributes:
- Durability, construction and material specification
- Size and weight
- Power supply and voltage
Your assessment should only consider the product’s normal intended use. In the exceptional circumstance that private household consumers may buy a product specifically designed for non-household use, its classification should be based on ‘reasonably foreseeable consumer behaviour’.
Importantly you must classify a product as either B2C or B2B. You cannot split your data to record your product as both B2C and B2B.
What should Producers do now?
- Assess product lines using the new classification system to determine whether each product is B2B or B2C.
- Consider any changes to category reporting since the introduction of the new WEEE Regulations in 2014 (i.e. lighting equipment).
- Look out for any future webinars & seminars ecosurety will be running on dual use here.
- If you would like tailored support to review your WEEE compliance, contact the WEEE compliance team on 0845 029 2228 or email WEEE@ecosurety.com.
You can read the full update from the Environment Agency here.
ecosurety was set up in 2003 (originally as Budget Pack) and specialises in sustainable business practice, driving efficiencies at every level for its 1,000-plus UK member companies.
Its market-leading integrated services span sustainable strategy, waste, compliance and intelligent reporting. In 2014 the company received the Institute of Directors' Corporate Responsibility Award for the South West.
By shaping and supporting best practice in waste and recycling ecosurety is driving greater efficiency in the resource cycle and reducing demand for raw materials. By 2020 ecosurety is targeting influence over 1 million tonnes of waste.
Innovation and policy director
Robbie is innovation and policy director at Ecosurety. Having spent years building an intimate understanding of the industry’s policies and politics, he uses this knowledge to help shape new legislation and oversees Ecosurety’s growing portfolio of cross-industry innovation projects including Podback and the Flexible Plastic Fund. He has worked closely with Defra during the most recent packaging consultations, outlining the impacts and required transitional arrangements of the UK’s new EPR system and is a member of the government’s Advisory Committee on Packaging (ACP). He is also a spokesperson for the company and regularly uses his influence to communicate the importance of environmental responsibility to external stakeholders.