The IT reseller community has a WEEE problem or more specifically, a Waste Electrical and Electronic Equipment problem - that is estimated to result in changes to the way that we deal with more a million tonnes of discarded electronics in the UK and significant changes to the way that many resellers do business. While the implications of the EU Directive are clear enough for most high street retailers selling to consumers, the practical realities for IT resellers are more complicated.
Paul James (pictured), general manager of DHLs environmental compliance solutions, looks at the impact WEEE could have on both resellers and their customers.
After much discussion, and some procrastination surrounding its implementation, the much-heralded WEEE Directive now finally looks likely to be introduced in 2007. Whilst the new WEEE Regulations are estimated to impact up to 100,000 businesses in the UK (25 per cent producers / brand owners and 75 percent retailers) who have business-to-consumer sales, the regulations also have implications for all businesses that use electrical equipment, which lets face it, is just about everyone.
And while much discussion has centred on the obligations businesses have for household waste, advice and guidance has been less forthcoming when it comes to business WEEE. Who pays for the collection, treatment and recycling of old equipment? Who needs to record the tonnage of waste and submit calculations to the regulatory agency? Who is responsible for meeting recycling targets on redundant electrical and electronic equipment and what are the penalties for non-compliance?
Lets start with what we do know. Resellers that sell direct to householders will have an obligation to provide take-back facilities for consumers to be able to return their replaced equipment on a like-for-like basis, regardless of the brand or where they purchased the old equipment. Many organisations look likely to join the Distributor Compliance Scheme, the contract to operate which is still being let by the DTI, which will provide funding to local authorities to take on the obligation to provide suitable return facilities. However, given the varying views on the volume that is actually likely to be returned to high street retailers, an increasing number are considering receiving equipment back to their stores. Whilst this option doesnt exist for distance sellers, a number are exploring the provision of a parcel collection service or a collection service on the delivery of the new item.
As well as being considered a distributor, many resellers will also be classed as a producer, where they place their own brand on equipment manufactured by others, import other organisations branded products directly, or are involved in the assembly of equipment. The later includes IT resellers that build PCs from component parts supplied or manufactured by others. In these instances, businesses will have to join a Producer Compliance Scheme (PCS), and pay for or undertake the collection, recycling and recovery of both their new equipment when it reaches the end of its life as well as the historic equipment, which will often be someone elses brand, that it is replacing now.
Where a producer sells to households, the PCS will collect discarded WEEE from designated collection facilities on behalf of its members. These sites will generally be local authority recycling centres or, if not part of the Distributor Compliance Scheme, nominated collection points set up by distributors or their service providers.
Where a producer sells to non-households, subject to the contractual arrangements they have in place with their customers, it will have to arrange for the collection of the old equipment from its point of arising. This will require IT resellers to be able to collect any quantity of products from any location in the UK. From two hundred monitors in Edinburgh to a single printer in Truro, resellers who are producers will need to be able to provide a collection service for discarded products on a like-for-like basis.
As far as the legislation is likely to be concerned, there will be very few obligations on resellers who solely sell to business users. However, the relationship that many resellers have with the brand owners whose products they resell may well see them pick up the producer obligation for these products on a contractual basis. Many brand owners, who have no direct link with the end users of their products are seeking to pass on the obligation to resellers to manage the end of life disposal of their products.
To make matters more complicated, certain electronic and electrical equipment, such as CRT monitors are classed as hazardous waste. This raises the possibility of IT resellers being liable to dispose of hazardous equipment, which may in turn require them to register as hazardous waste producers with the appropriate regulatory agency, as well as pick up the bill for its safe disposal.
To avoid picking up an obligation on old electrical equipment or, where this is unavoidable, paying over the odds for its collection, treatment, recycling and reporting, all businesses need to be considering now how they deal with the implications of the WEEE Regulations.
While the invention of the fax, telephone, computer and mobile phone have all made businesses more efficient, the issue of their safe disposal could prove costly if not managed properly.
DHL is offering a free advisory service for businesses on the implications of the WEEE Regulations.