WEEE/RoHS for B2B Company

Indium Corporation

From One Engineer to Another^®

WEEE/RoHS for B2B Company

Friday, April 8, 2005 by Dr. Ron Lasky [Dr. Ron Lasky]

Francis writes:

Dear Dr. Lasky,

I have read on several WEEE related sites that:

A "producer" is an entity which, irrespective of the selling technique (including by phone, ecommerce, digital television, m-commerce or retail outlets):

manufactures and sells EEE under its own brand; or
resells EEE under its own brand (and not that of the manufacturer); or
imports or exports EEE on a professional basis into a Member State (thereby potentially capturing non-EEA manufacturers or importers).

Considering these, here is my question:

We are a B2B company that sells in EU through Distributors only. We do not make any direct sales. It is obviously our responsibility to insure that our products will WEEE (and RoHS) compliant, but how does it work for the collection and recycling? Is it our responsibility to arrange and finance this, or is it our distributorâ

Comments for WEEE/RoHS for B2B Company

Sunday, April 10, 2005 by MA/NY DDave:: Hi Doc Ron, Francis, This is a bit tricky depending on your product and the final business (end product user) and their disposal techniques. It will also depend on the member state and how they might slightly adjust their laws. If not already registered I would register in those member states where your product has the highest volume if it carries your brand name. In those other states that you don't know much about or have low volumes the Distributor, importer, etc in or into that country will become the producer. Tricky without all the details. Yours in Engineering, Dave
Tuesday, April 19, 2005 by Joe:: I am very much interested in having this question better definec. Particularly, how what fits into the catagories of network infrastructure and telecommunications. More to the point a manufacturer that sells B2B, who manufactures high end SATCOM equipment and components should fit into this catagory, until the new technologies and qwerks have been completely worked out. Any comments on this would be appreciated.
Wednesday, April 27, 2005 by paul freeman:: we too are a manufacturer (of audio mixing cosoles)who sell into the EU through a distribution network - i asked the same question of Chris Tolady of the Department for Trade & Industry:- Mr. Tollady, we are a medium sized manufacturer who exports into most European countries through a network of distributors. Could you please answer a few questions we have regarding the WEEE directive? Who is responsible for the take-back of our product in EU countries other than the UK us or our distributor? It would be the distributor. If it is us do we have to register in all member states, or just the UK? Your distributors would need to register in the Member State they operate If we only have to register in the UK how will this work, for example in Germany, where they are ready to implement this in August year? See above If our distributor is responsible for take-back in their own country, and we change distributor will the new one then take on all the historic waste from the previous distributor? (this would make it hard for us to find new distributors, and when negotiating new contracts) In the UK, you would need to ensure that the new distributor took on responsibility for historic waste. However, other Member States may view this differently. hmmm the thick plottens... hope this adds to your debate. Paul Freeman. H&S Engineer, Allen & Heath Ltd. www.allen-heath.com
Sunday, May 8, 2005 by MA/NY DDave:: Hi Paul, I believe I have seen DTi's Chris's name before. From your input and my long learning on LF implementation, I seem to agree with everything DTi wrote to you in response. Some comments follow which seem to me to agree with DTi's Chris so I it seems like I am only writing in conformational agreement Chris. (Dang It!!) < It would be the distributor.> Yes

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