The WEEE Regulations state that:

“Producers of electrical and electronic equipment (EEE) are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users.”

If you put a product in scope of the WEEE regulations onto the UK market by any of the following:

• Manufacture and sell electrical and electronic equipment under their own brand.
• Resell, under their own brand, equipment produced by other suppliers.
• Import electrical and electronic equipment on a professional basis into an EU Member State. This includes imports into the UK from other EU member states

You must join a compliance scheme which will meet your WEEE responsibility for you by financing the safe disposal of all products at end-of life.

Recolight, who will manage this responsibility on your behalf.

It is your obligation as a producer to:

• Mark all EEE with the wheelie bin symbol
• Declare WEEE number to distributors
• Provide recycling information of all EEE
• Sign an annual declaration of compliance

A full list of your responsibilities can be found on the Environment Agency website.

• There is an initial process of registering on the Recolight Black Box secure website and returning signed copies of the Scheme Rules Agreement.
• The monthly data update will only take a few minutes each month via the Black Box.
• Thereafter Recolight will take care of your legal obligations on your behalf and provide information on an as-required basis to support your business.

All schemes must report data in a standard format to the enforcement agencies and we have designed our own formats in the same way as a matter of efficiency.

To demonstrate to the enforcement agencies that our data is correct we audit our members. This is done on a random basis and no more onerous than necessary to achieve the objective.

Black Box timeline of events

Monthly

Each month you are required to advise Recolight of your placed on market units and their aggregated weight. An accurate declaration must be made between the first and fifteenth day of each month, following the month end.

Environment Agency rules for declaring are:

• B2B All goods placed on market within any calendar year must be declared no later than 15 January of the year following.
• B2C All goods placed on market must be declared quarterly.
• If your company is declaring B2C, then regardless of unit quantity, you must declare these figures quarterly.

Annual confirmations

An annual confirmation is a confirmation of the information your company has supplied to us throughout the previous year, summarised on a single page document.

You carry out this process after the 16 January each year and have up until the 15 February to complete. It takes just a few minutes.

This is an EA requirement.

Annual Declaration of Compliance 

The annual declaration process starts around the first week of September each year, and you have until 16 November to complete. All members are emailed a document with questions; this must be printed, answered, signed by a director or senior manager and then scanned or posted to Recolight.

The WEEE Regulations affect everybody in one way or another but the primary groups affected are:

• Producers, who become responsible for financing the end-of-life treatment of their products
• Distributors, who become responsible in some cases for taking-back end-of-life products when new products are purchased and for providing information to users about the need for recycling and facilities for the disposal of end-of-life products.

A producer is the party which first puts Electrical or Electronic Equipment (EEE) onto the UK market, whether they are manufacturers of EEE, private brand distributors or importers. The primary responsibility is to finance the environmentally sound disposal of their products at end-of-life.

A producer is any person who:

• Manufactures and sells electrical and electronic equipment under their own brand.
• Resells, under their own brand, equipment produced by another supplier.
• Imports electrical and electronic equipment on a professional basis into an EU Member State.

Producers of Electrical and Electronic Equipment (EEE) as listed in Schedule 2 of the UK WEEE Regulations are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users. There are some exemptions and limits to this that can be found in the detail in the Regulations. For Example: non-Household WEEE where there is no like-for-like replacement.

Producers must join a Compliance scheme (or provide their own Environment Agency approved scheme) which will meet this responsibility by:

• Managing and paying for the recycling and recovery of their share of this WEEE,
• and report on what they have done to the appropriate Government authority.

Full details may be found in the BIS Guidelines.

LEDs and OLEDs were by the Environment Agency as “in scope” for the WEEE regulations in May 2009.

As a result, companies importing or producing LED and OLED lamps need to comply with the WEEE regulations now.  Recolight membership ensures that LED, OLED and LED luminaire producers are compliant with the law, and that they can also offer free recycling to their customers.

Household luminaires come into scope of the WEEE Regulations in 2019.