The Environment Agency, with support from WEEE compliance schemes, have updated their support document for the WEEE regulations. The new guidance clarifies changes happening from 1 January 2019 under the new Open Scope requirements.
This latest guidance offers increased clarity and is to be used by key stakeholders responsible for the reporting of EEE.
The new Open Scope changes coming into force next year are set to impact a large number of producers, especially as a number of products that were previously excluded will now be coming into scope of the regulations.
The latest guidance from the EA clarifies these changes and the main updates to be aware of are highlighted below.
Clarification on the definition of EEE
The definition of EEE has not changed with the new Open Scope guidance, but there is additional clarification. For example, if a product can no longer work properly when the electricity is turned off, it is in scope. This gets more interesting however when considering a product that has more than one function and not all of them depend on electricity to work, for example in the case of furniture and clothing. We recommend our members to highlight these products with our team for scoping advice.
Switches and sockets now in scope
It has now been confirmed that electrical wiring accessories will be in scope from 2019, including switches and sockets, and will be reportable in category 2 (Small Household Equipment). These products were previously out of scope if it did not have additional functionality such as a neon light or a charging connection.
Large Scale Fixed Installation clarified
Large Scale Fixed Installations are remaining out of scope, but new guidance helps to determine what is included in this exclusion. Essentially it will need to meet the criteria for ‘large size’ as defined in the RoHS FAQ document.
Any equipment that forms part of a Large Scale Fixed Installation that is not specifically designed for it, is not integral to its operation and can still operate correctly in its own right, is an EEE product and must be reported. This could include such items as a display screen or a solar panel.
Household B2C lighting now in scope
Under the existing scoping rules B2B lighting is in scope whilst B2C light is not. From 1 January 2019 however, B2C lighting will be in scope and reportable under Category 5, so it is crucial that producers of lighting review all their products and scoping methodology carefully.
Non-electrical accessories no longer included
Previously non-electrical accessories placed on the market with an electrical product were required to be included when reporting the product. This is no longer the case, and items such as a plastic water jug sold with an electric iron will no longer need to be included when reporting.
There is an important exception however. If the accessory is integral to the operation of the product then it must be included. This impacts items such as shelving inside fridges or a stand for a TV.
Carefully consider your products now
Client services manager Abigail Warren commented “We strongly advise all EEE producers to carefully consider all their products ready for the 2019 reporting period, especially if they were previously excluding any products as these may well fall into scope now.
Although the new guidance adds plenty of new detail which will help a great deal, we are aware that there are still some areas that will require careful consideration to scope correctly. We are recommending all our WEEE members to start looking at this now, our team are on hand to provide support for this as required.”
It must also be noted that the new guidance and Open Scope rules will only take effect from the 2019 reporting period. When reporting 2018 Q4 data at the start of 2019, the new rules will not apply.
If you have any questions or would like assistance now to prepare for Open Scope, please contact our team.
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