DELIVERING THE LIGHTING INDUSTRY’S SOLUTIONS TO THE WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT LEGISLATION (WEEE)

Created for INDUSTRY by INDUSTRY

WEEE FAQs

Note: Lumicom has taken care to ensure that the answers to the questions listed below are reasonably comprehensive and accurate. Please note that answers to FAQs are published in good faith for guidance only and represent current thinking based upon present knowledge. As more information becomes available the answers will be updated from time to time. All enquirers should ultimately rely upon their own legal advice in reaching any interpretation of the regulations or determining policies of their business. The UK WEEE Regulations SI 3289:2006 and BIS Guidance [see Useful Links page] should be consulted).

PRODUCERS/MANUFACTURERS

Q. What is the effective date of implementation of the WEEE Regulations?

A. The Regs were enacted on 2nd January 2007 with full implementation of producer responsibility for financing environmentally sound disposal of products at end-of-life began on 1st July 2007.

Q. What is the difference between historic and future waste?

A. Historic waste is product installed before 13.8.05 and future waste is the equipment installed from 13.8.05. The latter will be distinguished by the WEEE mark:

Q. Is the producer responsibility the same for historic and future waste?

A. No, for historic waste the producer of the replacement equipment has the responsibility for financing a disposal infrastructure that will accept the historic waste.

If there is no replacement equipment, responsibility for the disposal of the discarded equipment, lies with the end user.

For future waste, the producer of the discarded equipment is responsible for financing an infrastructure that will ensure environmentally sound disposal.

Q. What happens if financial surpluses start to build up in Lumicom?

A. We will retain sufficient reserves to satisfy the robustness test but then probably reduce charges. We have no interest in big reserves as we cannot distribute them in any way as we are a not-for-profit company.

Q. How will enforcement be policed?

A. The Environment Agency will be policing the WEEE Regulations as they are the appointed enforcement agency and have been given the powers and resources to carry out that enforcement.

Q. Are there penalties for those who don’t comply?

A. Yes, within the Regulations the EA can impose fines and ultimately prosecute those who ignore or abuse the regulations.

SCOPE

Q.How can a producer decide if his lighting equipment is within scope?

A. The Decision Tree has been compiled by the industry for the benefit of lighting producers, enabling them to judge which of their equipment is in scope of the WEEE Regulations and which is out of scope. To use decision tree click here.

WHOLESALERS

Q. How do the UK WEEE Regulations affect the electrical wholesaler?

A. Providing that the electrical wholesaler does not import or place his branded EEE on to the UK market, he is largely unscathed by the Regulations. However, it is recommended that wholesalers:

Alert their suppliers of EEE of the need to show their WEEE Registration numbers on their invoices
Review their terms and conditions of purchase and the terms and conditions of their suppliers to ensure that they are not undertaking WEEE obligations they do not wish to undertake. The default in the WEEE Regulations is that the producer is responsible for WEEE obligations and financing thereof, but it is possible for alternative arrangements to be made by agreement. If you do not wish to accept any WEEE producer responsibility for disposal, except in the case of electrical equipment that is sold under your own brand, you should consider putting a clause in your purchase conditions to reflect that.
Review their list of approved suppliers to ensure they are all fully WEEE compliant in their own right and are not seeking to pass their producer responsibility down the supply chain.

RECYCLING

Q. Are all producers members of Lumicom?

A. No, some joined other Schemes, but the majority supported Lumicom.
(The Regulations pose problems for companies who have multiple categories of EEE in their product portfolio in that it is not possible to be a member of two Compliance schemes for B2B obligations or for B2C business applications. For example a number of companies selling both Luminaires and Lamps had to choose between Lumicom or Recolight, depending on where the majority of their business interests lay).

Q. What is the end user’s responsibility?

A. The end user is responsible for the environmentally sound disposal of discarded historic luminaires when there are no replacements.

Q. How does the Lumicom recycling service work?

A. Click [here] to view the 'at a glance' flow chart of how the Lumicom scheme works.

Q. What different arrangements do I have to make if I already have a skip for light metals in my depot/yard?

A. Keep a note of the number of luminaires and lanterns that you put in the skip. Instruct your skip provider to deposit the skip’s contents at an EMR Waste Transfer Station, download a delivery note from the Lumicom website and give it to your driver to hand to EMR when they deliver the waste to EMR. In due course, EMR will provide Lumicom with an evidence note in respect of that delivery.

Q. What happens to the discarded luminaires and lanterns when they are recycled?

A. It is not normally economic or environmentally sensible to reuse old equipment. Generally speaking modern replacements will produce a better light output and use half as much electricity. The vast majority of discarded lighting equipment is shredded into small pieces of metal and plastic and sold on the world market as raw material. Most of it ends up in the Far East where it goes back into manufacturing.

The composition of a typical non household luminaire would be:

Ferrous 50%
Non ferrous 22%
Plastic 21%
Glass 7%

GENERAL

Q. What does WEEE stand for and what are the WEEE Regulations about?

A. WEEE is an acronym for Waste of Electrical and Electronic Equipment. The WEEE Regulations stem from an EU Directive of the same name and that Directive is being rolled out in all EU countries.

Q. How is Lumicom encouraging the reuse of lighting equipment?

A. In the generality of things, it is not environmentally sensible to reuse obsolescent luminaires. Modern lighting technology is twice as energy efficient as that installed 20 years ago. The exception occurs where the wiring and control gear can be replaced.

Q. What is a non household luminaire?

A. It is a lighting fitting installed in a non-household application eg offices, factories, shops, streetlighting etc., and these mostly are designed specifically to embody efficient, long-life gas discharge lamps. There are exceptions eg:

Under the Regulations, WEEE from private households includes WEEE from commercial, industrial, institutional and other sources which, because of its nature and quantity, is similar to that from private households, so effectively small, non-household applications are treated as household.
Lighting fittings incorporating a filament lamp, but used in a non-household application, would also be classified as a non-household luminaire, subject to the above exemption.

Q. What benefit does the end user get when recycling?

A. A better future environment, eg less landfill with its various problems and better use of finite materials resources. The Government has been promoting a greener environment for many years and it is in the best interests of everyone to recycle the product at end of life.