Transcript Document

WEEE Directives
(EAUC Seminar, University of Edinburgh, July 11th 2007)
Executive Summary
Ronan Rafferty (MCIPS)
Purchasing Section
University of Ulster
1
Aims
• Summarise the key points of the WEEE Regulations 2006
legislation.
• Highlight potential challenges and risks of a fundamentally
changed landscape.
• Explore case studies evidence showing how other HE institutions
are planning to tackle the issue.
• Hopefully provide the building blocks of a process which will
enable the University to fully comply with the legislation.
2
WEEE MAN
3
What is the new WEEE legislation
?
The Waste Electrical & Electronic
Equipment Regulations 2006
(EU WEEE Directive Transposed into UK Law)
4
A “good” EU Directive !
Waste Electrical and Electronic Equipment
(WEEE) Directive (2002/96/EC)
&
Restriction of Hazardous Substances in
Electrical and Electronic Equipment
(2002/95/EC)
Implemented by the Restriction of the Use of Certain Hazardous
Substances in Electrical and Electronic Equipment Regulations 2006
5
Main Players
• Government – DTi (responsible for implementation)
• DEFRA (approving authorised treatment facilities only)
• Environment Agency / SEPA / EHS (regulating compliance
schemes)
•
•
•
•
Businesses – producers and end users
‘Compliance Schemes’
Retailers
Local Authorities
6
Guidance
• Regulations finally came into force
on 2nd January 2007
• Producer responsibility began 1st
July 2007
• Guidance available on DTi website
7
Why are (WEEE) Regulations 2006 Important?
• As of 1st July 2007 any organisation that buys or disposes of
Electrical or Electronic Equipment (EEE) such as;
IT, audio-visual, white goods or laboratory instrumentation must be
in full compliance with the legislation.
• Legislation places responsibilities on institutions in relation to the
recovery and recycling of all WEEE equipment.
• WEEE legislation raises issues concerning contract negotiations
for the supply of new electrical and electronic equipment in terms
of who takes responsibility for financing recovery and recycling.
8
Scope
All equipment dependent on electrical currents or electromagnetic fields.
10 indicative categories * :
•
•
•
•
•
•
•
•
•
•
Large household
Small household
IT and telecommunications
Consumer equipment
Lighting equipment
Electrical and electronic tools
Toys leisure & sports
Medical devices
Monitoring equipment
Automatic dispensers
A non-exhaustive list of examples is also given in Schedule II of the Regulations at
http://www.opsi.gov.uk/si/ si2006/20063289.htm#sch2.
9
Specific Exemptions
• Exemptions:
•
•
•
•
•
•
National security / military equipment
Stationary industrial tools
Luminaries in households
Implanted or infected medical products
EEE that forms part of equipment that is not in scope
Filament light bulbs and household luminaries (note that
these are NOT exempt from RoHS)
• Also:
• Main power source must be electricity
• Electricity needed for primary function
• Not part of another type of equipment or fixed installation
10
DTi Guidance - Scope
11
Producers and End-Users
-
The legislation makes producers of electrical and
electronic equipment responsible for the financing of
the recovery and recycling of such equipment at the
end of life.
- From 1st July 2007, in certain circumstances, the
regulations also place responsibilities on end-users
of WEEE to be responsible for the recovery and
recycling of this equipment when it becomes waste.
12
Business User Obligations
• Business users will be responsible for some historic waste
• What is Historical Waste?
– Waste products placed on the market before 13 August
2005
• Historical WEEE (placed on the market before 13 Aug 2005)
– If no like for like replacement the end business user is
responsible for disposal costs
– If like for like replacement of equipment – supplier (producer)
responsible
• New Business WEEE (placed on the market after 13 Aug 2005)
– Producer responsible, unless otherwise agreed with business
13
user
14
Challenges
• Do your purchasing systems allow you to trace back
when equipment was purchased and from whom?
• Determining when something was ‘placed in the
market’ is likely to be problematic
• Contacting / identifying historical suppliers to take
away your historical waste may be problematic
• Identifying ‘the Producer’
15
‘Like for Like’
• Fulfils the same function
• Need not be identical in all respects
• Take account of technological developments and
improvements in functionality
• Common sense / practical approach
• Acceptable examples: VCR – DVD, walkman / iPod
• Unacceptable examples: TV – drill, washing machine
- kettle
16
Duty of Care
• Amendments under the Duty of Care have been recently
consulted upon
• Business users would have to keep proof to demonstrate that
one off consignments of WEEE have been disposed of to an
accredited re-processor
• Practical considerations:
– Segregating WEEE from the main waste stream
– Separating WEEE which is your responsibility and a
producer / suppliers responsibility
17
Third Sector (Charities)
• If the equipment is still functional it is not waste and
can therefore be given to charities ?
• Compliance Schemes encouraged to use charities
and state how they will encourage the re-use of
whole appliances in their applications
18
End Users Beware!
• The Regulations allow suppliers (producers) to negotiate
alternative financing arrangements
– This will be a commercial decision and should form part of
the supply contract negotiating process
• Some (unscrupulous!) producers may try and discharge their
recycling obligation by writing into supply contracts that their
customer is responsible for re-cycling WEEE at the end of its life
– Contracts must be negotiated carefully
– Purchasing Staff need to be made aware
19
Summary – 4 scenarios to plan for
1. WEEE purchased before Aug 2005 that you are not
replacing with like for like equipment
2. WEEE purchased before Aug 2005 that you are
replacing with like for like equipment
3. WEEE purchased after Aug 2005 that you are not
replacing with like for like equipment
4. Negotiations with suppliers for EEE purchased in the
future
20
1. WEEE purchased before Aug 2005 that you are not
replacing with like for like equipment
• Your responsibility
• Compliance schemes can be used for one off collections of WEEE
(or contact AATF directly)
• Many compliance schemes registered with the EA and specialise in
different types of waste / different commercial situations
• Find the most appropriate scheme for you (cost / evidence of proper
disposal / IT equipment – confidentiality / destruction of sensitive
data)
• Retain evidence of appropriate disposal via Duty of Care
21
2. WEEE purchased before Aug 2005 that you are
replacing with like for like equipment
• Producer (new supplier) is responsible, regardless of
whether they supplied you with the original
equipment
• Contact new supplier and arrange collection of waste
as well as delivery of new like-for-like equipment
22
3. WEEE purchased after Aug 2005 that you are not
replacing
Original producer (supplier) is responsible regardless of whether
a like for like replacement is taking place
• Contact supplier and arrange collection (may need to get this
information via your distributor)
•
NB: Determining when something was ‘placed on the market’ may
cause problems – in these situations, for practical purposes,
establishments may want to make the executive decision to dispose of
all historical EEE themselves, particularly given that many compliance
schemes will collect free of charge
23
4. Future purchasing of EEE
• Ensure you address the issue of disposal of the equipment at
end of life is included in the contract
• Can be used as an additional negotiating tool
• Ensure producers do not try and discharge end of life disposal
obligations to you in the small print
• Ensure purchasing systems are set up to record dates of
purchase and supplier information
24
Main points
• Possible producer obligations
– Register with a compliance scheme if necessary
• Main obligation as business user
– Establishing internal systems for understanding when waste
electrical equipment was purchased
– Negotiating supply contracts for future supplies
– One-off collections using a compliance scheme / AATF
– Separation / storage of WEEE
– Obtain evidence of correct disposal
25
Case Study 1 (University of Glasgow)
•
•
•
•
•





The sheer scale of the challenge
Lack of awareness & understanding
Purchasing and Legal requirements
Asset tracking and record keeping
Disposal
Complexity – large No. of people, depts & budgets
The huge no. of items.
Geographical/physical issues
The culture
The range of activities
26
Step 1 - Addressing awareness & understanding
(University of Glasgow)
• Legal requirements
 Duty of Care training
 Selection and audit of contractors for disposal
 Encourage use of existing approved contractors
27
Step 2 - Addressing administrative &
management issues (University of Glasgow)
• Encourage linking to PAT and assets register
databases.
• Utilise Agresso financial records
• Educate departments on retention of Transfer
Notes. Periodic audit of departments.
28
Step 3 – Addressing Disposal
(University of Glasgow)
• Uplifts from each department and building
• Environmental and sustainability issues a
high priority. The issue of charities
• Costs associated with these small
uncoordinated uplifts
29
Step 3 – Addressing Disposal
(University of Glasgow)
• Disposal of highly specialist equipment on a case
by case basis initially
• Review disposal quantities and costs after ~18
months
• Tender for framework agreement for disposals
30
Case Study 2 (University of Exeter)
PROCUREMENT INFLUENCES:-
•
Communication
•
Waste Matters – Environmental Seminar
•
Sustainability Committees’
•
Appointment of Sustainability Adviser
•
WEEE ‘round-up’s’ (2006)
•
Tender clause
•
Contract Waste / Recycling Solution
31
OBJECTIVES (Exeter)
•
Procurement Strategy of how
we intend or propose to
comply with the WEEE
Regulations
• WEEE Audit
• Partnering
Arrangements
• Reduction in Carbon
Footprint / Co2
emissions
• Advantages / Quick
Wins
• Lease / Rental IT
Equipment UoP
32
Case Study 3 (University of Edinburgh)
Objectives:• To make the purchasers and end users of
equipment aware of the WEEE Directive and of
our responsibilities and challenges
• To ensure that the suppliers who deliver to the
University have registered with a scheme (e.g.
Valpak) - only 30% done so to date
• To ensure that WEEE is disposed of at the
lowest cost to the University whilst conforming
to DoC / good practice
33
Our Challenges
•
•
•
•
Awareness of users/purchasers
No common inventory of items under £25k
Unauthorised / unregistered equipment
Unauthorised disposal methods (skip,
charities)
• Disposal costs (who? / when?)
• Quantity and variety of WEEE
• Details of compliance schemes geographical
and space constraints
34
FAQ’s
35
FAQ’s (2)
• level.
36
FAQ (3)
37
Further Information
38
39
40
Thank you for your attention
Any questions?
[email protected] (ext 24239)
For further information please see:
http://www.ulster.ac.uk/purchasing/
41