Following the recast WEEE Directive, all member states in Europe are required to adopt open scope.
All electronic and electrical products will now be reported as in scope, unless they are specifically out.
Until now, if certain items did not fit in to one of the defined categories, they were automatically out which left large sections of the WEEE recycling stream unfinanced. The EU’s aim was partly to capture these previously excluded items and ensure producers are paying a fair share, and to try and harmonise reporting across Member States.
Implementation from 15th August
From 15th August 2018, the majority of EU countries will be implementing open scope. Producers will need to declare all their products unless they have good reasons for excluding them. The UK will be implementing the change in January 2019.
With some exclusions
The following exclusions remain in force, but clear reasoning must exist for relying on them:
- Equipment for security of member states (i.e. munitions, arms, military material)
- Equipment specially designed and installed as part of another device to which the WEEE Directive is not applicable and operating as intended only as part of that device (e.g. built in vehicle navigation systems)
- Filament bulbs
- Equipment designed to be sent into space
- Large scale stationary industrial tools (e.g. newspaper printing presses, cranes)
- Large-scale fixed installations (e.g. airport conveyor belts / elevators / escalators)
- Means of transport for persons / goods (e.g. cars, motorhomes, lorries)
- Non-road mobile machinery
- Equipment designed for specific research and development
- In-vitro diagnostic and other medical devices expected to become infective before end of product’s life
Previous exclusions (such as household lights or ‘luminaires’) have been removed and these products must now be declared.
Six new categories
The old ten reporting categories were more function-based, whereas the new six categories are more size-oriented:
- Temperature Exchange Equipment
- Screens, monitors and equipment containing screens having a surface area greater than 100cm2
- Lamps (light bulbs)
- Large Equipment (any external dimension more than 50cm)
- Small Equipment (no external dimension more than 50cm)
- Small IT and Telecommunication Equipment (no dimension more than 50cm)
Please be aware however that authorities in each Member State are still free to adopt sub-categories within the main six above.
Get ready for open scope reporting
What steps should you take in readiness for the new open scope reporting? Firstly, check with your overseas schemes which categories you should be reporting in to. This is particularly relevant if the authorities in certain countries have adopted sub-categories whilst others have not. Secondly, revisit your product database. Check whether any of your products were previously out-scoped in reliance on an exclusion, and whether that exclusion remains valid. Finally, re-categorise your products bearing in mind the new size-based criterion of above/below 50cm diameter, and be ready to report your products into the new categories.
Don’t forget to liaise with your overseas schemes to make sure you are giving them the information they require before the first reporting deadline.
If you need guidance with scoping of your products or assistance with registering overseas, please contact our team.
International project manager
Katie manages our expert international compliance services to help ensure our members are compliant with recycling legislation overseas. She has a sharp pair of eyes too, having previously qualified not only as a chartered legal executive but also in PRINCE2 and APM project management. When the devil is in the detail, Katie ensures nothing is missed!