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Defining if your equipment falls under WEEE Directive (2012/19/EU)

Craig Whitehead

Hi There,

My company is undergoing a CE review and we have engaged with a consultancy who have found a few minor gaps in our tech file and processes (so overall a worthwhile process), however they believe our manufactured equipment comes under WEEE and RoHS.

We make industrial equipment shipped around the world, with a very small installed base in the UK. our equipment:
  • Is only sold to industrial users for incorporation into product filling lines
  • Is a mechanical action machine that cuts, forms and delivers caps to filled bottles
  • The machines are Electronically controlled via HMI / PLC, utilising servo and vfd driven motors from a control cabinet or supplied panel
  • The equipment is wired to plant mains (usually 400V 30A feed) 
  • The machines are free standing but bolted down and attached to the filler / sealer via the cap delivery chute
  • The machines are approximately 2 - 2.5m tall, and weigh between 0.5 to 1 Ton
  • Our machines do not have an expected lifecycle (we still have equipment supplied in the 1970's in production) 
  • We have not supplied new machinery to a UK site for over 6 years, majority has been outside of the EU as final destination

As such, we did / do not believe the machine comes under WEEE.  

All Electrical / electronic components used are RoHS / WEEE / CE compliant from major manufacturers such as Siemens, AB, Wenglor etc)

All parts / materials used are RoHS compliant, but we believe the machine itself does not come under RoHS as a whole.

Anybody able to shed light onto which side we fall onto?

Parents
  • 0

    Hi Craig,

    Hmm. It sounds from your post as if the key issue is going to be whether your equipment can be counted as exempt because it counts as 

    "large-scale stationary industrial tools"
    "large-scale fixed installations which perform specific industrial operations"

    https://www.gov.uk/guidance/regulations-waste-electrical-and-electronic-equipment

    and

    "large-scale stationary industrial tools and large-scale fixed installations"

    https://www.gov.uk/guidance/rohs-compliance-and-guidance

    I think I'd probably give the same advice as your consultant (in fact I did give this advice last year to a client in a roughly similar position to yours) - it should be really easy completing the WEEE and RoHS compliance (since fundamentally you're just going to state that the sub-assemblies are and pass the WEEE measures on), so it's probably less risk doing that than someone at some point deciding that they are not "stationary / fixed" which would then land you in trouble. Having always worked in the supply of equipment for fixed installations, with typical service lives of 25 years plus, I've still always found it's easier to just do the WEEE and RoHS compliance than to try arguing your way out of it.

    But that said, yes it would be reasonable to go back and at least ask your consultant why they consider your equipment doesn't meet those criteria.

    Unless of course you are definitely not going to sell it into the UK or EU again, in which case of course you don't need to.

    Hope that helps a bit.

    Thanks,

    Andy

Reply
  • 0

    Hi Craig,

    Hmm. It sounds from your post as if the key issue is going to be whether your equipment can be counted as exempt because it counts as 

    "large-scale stationary industrial tools"
    "large-scale fixed installations which perform specific industrial operations"

    https://www.gov.uk/guidance/regulations-waste-electrical-and-electronic-equipment

    and

    "large-scale stationary industrial tools and large-scale fixed installations"

    https://www.gov.uk/guidance/rohs-compliance-and-guidance

    I think I'd probably give the same advice as your consultant (in fact I did give this advice last year to a client in a roughly similar position to yours) - it should be really easy completing the WEEE and RoHS compliance (since fundamentally you're just going to state that the sub-assemblies are and pass the WEEE measures on), so it's probably less risk doing that than someone at some point deciding that they are not "stationary / fixed" which would then land you in trouble. Having always worked in the supply of equipment for fixed installations, with typical service lives of 25 years plus, I've still always found it's easier to just do the WEEE and RoHS compliance than to try arguing your way out of it.

    But that said, yes it would be reasonable to go back and at least ask your consultant why they consider your equipment doesn't meet those criteria.

    Unless of course you are definitely not going to sell it into the UK or EU again, in which case of course you don't need to.

    Hope that helps a bit.

    Thanks,

    Andy

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