On 2 January 2007 the Waste Electrical and Electronic Equipment
Regulations 2006 come into force. The burden it puts on small
businesses is draconian. Businesses of all sizes have only until until
15 March 2,007 to join an approved Producer Compliance Scheme. Total
cost of the whole compliance package £1 - 2k in annual membership
charges before a single printed circuit board has been recycled.

There is no minimum company size; the regulations apply to all
producers whatever their turnover, market share or number of
employees.

For us the cost of doing this is out of proportion to the profit
generated by our equipment sales so we are considering withdrawing our
product from the market. However we will still have a reasonable
business in supplying spare parts and service for machines sold over
the last 20 years. Unfortunately the information on government web
sites appears to have been written by the Bosnian Serbs, and the
commercial sites contradict each other, are sometimes out and out
wrong and can not be regarded as impartial.

It's a criminal offence not to register before 15th of March, so ...

Please, does anybody happen to know:

Is repairing a 12 year old machine using new spare parts "Putting a
product onto the market", thus requiring registration ?

Is selling new spare parts for a customer to repair his 12 year old
machine "Putting a product onto the market".

DG

On 2007-01-29 20:47:40 +0000, Derek Geldard said:

On 2 January 2007 the Waste Electrical and Electronic Equipment
Regulations 2006 come into force. The burden it puts on small
businesses is draconian. Businesses of all sizes have only until until
15 March 2,007 to join an approved Producer Compliance Scheme. Total
cost of the whole compliance package £1 - 2k in annual membership
charges before a single printed circuit board has been recycled.

There is no minimum company size; the regulations apply to all
producers whatever their turnover, market share or number of
employees.

For us the cost of doing this is out of proportion to the profit
generated by our equipment sales so we are considering withdrawing our
product from the market. However we will still have a reasonable
business in supplying spare parts and service for machines sold over
the last 20 years. Unfortunately the information on government web
sites appears to have been written by the Bosnian Serbs, and the
commercial sites contradict each other, are sometimes out and out
wrong and can not be regarded as impartial.

It's a criminal offence not to register before 15th of March, so ...

Please, does anybody happen to know:

Is repairing a 12 year old machine using new spare parts "Putting a
product onto the market", thus requiring registration ?

Is selling new spare parts for a customer to repair his 12 year old
machine "Putting a product onto the market".

DG

I've looked at this whole area at many times in the past - originally
in connection with the EMC Directive.

Placing a product on the market is one or more of:

- Manufacturing within the EU and selling it directly or through a channel

- Importing it and selling it as a subsidiary of a company established
outside the EU

- If you are a reseller, distibutor,... importing it from a
manufacturer outside the EU and selling it.

Neither of the scenarios you describe constitute placing the product
onto the market - i.e. you can supply spares and repair.

In the context of the rest of it, to be honest, I would take a
commercial view. The EMC Directive was bad enough. WEEE aspires to be
a shambles.

I think that there are three courses of action

- Take product off of market

- Look at registration and the commercial implications.

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K
is absolute worst case for this. I haven't looked at WEEE in this
regard, but for sure is you are a small business there are much bigger
fish for the jobsworths to fry.

If the product isn't that lucrative then certainly take it off the
market, but I wouldn't feel bullied about that.

"Andy Hall" wrote in message
...

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K is
absolute worst case for this. I haven't looked at WEEE in this regard,
but for sure is you are a small business there are much bigger fish for
the jobsworths to fry.

If going down this route, presumably it would be sensible to do some of the
appropriate bits - eg the little bin sticker, and maybe ensuring the
customers know to send it back to you at the end of its life/arranging for
suitable disposal.

cheers,
clive

"Clive George" wrote in message
...
"Andy Hall" wrote in message
...

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K is
absolute worst case for this. I haven't looked at WEEE in this regard,
but for sure is you are a small business there are much bigger fish for
the jobsworths to fry.

If going down this route, presumably it would be sensible to do some of
the appropriate bits - eg the little bin sticker,

Do you mean the little 'not' bin logo.

Does anyone really think that the average punter is going
to take any notice of this and 'not' put a broken remote
contol in the bin?

tim

"tim....." wrote in message
...

"Clive George" wrote in message
...
"Andy Hall" wrote in message
...

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K
is absolute worst case for this. I haven't looked at WEEE in this
regard, but for sure is you are a small business there are much bigger
fish for the jobsworths to fry.

If going down this route, presumably it would be sensible to do some of
the appropriate bits - eg the little bin sticker,

Do you mean the little 'not' bin logo.

Does anyone really think that the average punter is going
to take any notice of this and 'not' put a broken remote
contol in the bin?

That's not why I suggested doing it - it's one of the requirements, and I
was suggesting that if one had taken care to do what one could, it would
stand in your favour should people catch you.

cheers,
clive

"Clive George" wrote in message
...
"tim....." wrote in message
...

"Clive George" wrote in message
...
"Andy Hall" wrote in message
...

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K
is absolute worst case for this. I haven't looked at WEEE in this
regard, but for sure is you are a small business there are much bigger
fish for the jobsworths to fry.

If going down this route, presumably it would be sensible to do some of
the appropriate bits - eg the little bin sticker,

Do you mean the little 'not' bin logo.

Does anyone really think that the average punter is going
to take any notice of this and 'not' put a broken remote
contol in the bin?

That's not why I suggested doing it - it's one of the requirements, and I
was suggesting that if one had taken care to do what one could, it would
stand in your favour should people catch you.

Yes, I know.

I was just asking the question generally.

Does anyone really think that by putting a little symbol
on a 'throw away' electrical item that I won't throw it away?

It's not like they will come and collect it from me and AIUI,
(unlike in other EU countries) I don't even get the option to
take it back to an electrical shop but have to take it to some
'special' place, which I have little doubt will be the council tip.

tim

tim..... wrote:

Do you mean the little 'not' bin logo.

Does anyone really think that the average punter is going
to take any notice of this and 'not' put a broken remote
contol in the bin?

Last I read, disposing of WEEE in a wheelie bin *is* actually considered
acceptable for a consumer (although not a business).

--
Cheers,

John.

/================================================== ===============\
| Internode Ltd - http://www.internode.co.uk |
|-----------------------------------------------------------------|
| John Rumm - john(at)internode(dot)co(dot)uk |
\================================================= ================/

On Mon, 29 Jan 2007 21:25:48 +0000, Andy Hall
wrote:


- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K
is absolute worst case for this. I haven't looked at WEEE in this
regard, but for sure is you are a small business there are much bigger
fish for the jobsworths to fry.

I.e. he is an easy target. Remember that guy who was prosecuted for
making computers that didn't meet EMC?

Derek Potter writes:

I.e. he is an easy target. Remember that guy who was prosecuted for
making computers that didn't meet EMC?

No. Do tell.

Jon

On Mon, 29 Jan 2007 22:15:25 GMT, Jonathan Schneider
wrote:

Derek Potter writes:

I.e. he is an easy target. Remember that guy who was prosecuted for
making computers that didn't meet EMC?

No. Do tell.

The ones I heard of were small time PC system builders on High Streets
who fitted extra peripherals without going through re-testing, or
fitted a different model PSU F. I.

A system buit from CE marked sub-assemblies ! = a CE compliant system.

DG

On 2007-01-29 23:54:29 +0000, Derek Geldard said:

On Mon, 29 Jan 2007 22:15:25 GMT, Jonathan Schneider
wrote:

Derek Potter writes:

I.e. he is an easy target. Remember that guy who was prosecuted for
making computers that didn't meet EMC?

No. Do tell.

The ones I heard of were small time PC system builders on High Streets
who fitted extra peripherals without going through re-testing, or
fitted a different model PSU F. I.

A system buit from CE marked sub-assemblies ! = a CE compliant system.

DG

Precisely. The whole thing is a nightmare even for manufacturers.

RF emission and susceptability changes also according to what is
connected and the cables so one really needs to test a complete system.

In practice, most manufacturers test a few typical configurations as it
isn't realistic to test all combinations.

On Mon, 29 Jan 2007 21:25:48 +0000, Andy Hall
wrote:

Thanks for joining the thread.

I've looked at this whole area at many times in the past - originally
in connection with the EMC Directive.

We've been through all that prior to 1996. In fact in 1989 The NHS
insisted we had our product type tested to IEC 601 by TUV in Germany .
We did that, it put up the cost of the product 19% in respect of a
myriad of sticky labels, silk screened legends, changes to manuals and
some changes which really only related to Europe with their reversible
mains plugs, USW, USW, USW.

Then the NHS went to the competition for machines because they were
cheaper (but no type testing) when we challenged them on that the 24
year old Girls (One of which admitted to me she'd never seen an X-ray
machine in her life, so that's why she had to go to the X-Ray show in
Chicago) that they had in NHS supplies said "Oh he's retired now, I
never actually met him". She was only in her post for 15 months or so,
she's left now. 8-(

We did the EMC & Low Voltage directive in 1995, and in 1998 got ISO
9,000 cetificated. In 2,000 they re-wrote ISO 9,000, so in 2,002 we
had to do it again from scratch. It's gone out of fashion now and
we've not ben asked about it since then but we still have to pay £500
every year for some old geezer to come and waste half a day in the
office looking at delivery notes and service dockets. He gave us a non
compliance notice 2 years ago because I'd left the cover off of my PC,
because of suspected overheating problems (Turned out to be bad
memory) .

Heard the story about the last straw and the camel's back ?


Placing a product on the market is one or more of:

- Manufacturing within the EU and selling it directly or through a channel

- Importing it and selling it as a subsidiary of a company established
outside the EU

- If you are a reseller, distibutor,... importing it from a
manufacturer outside the EU and selling it.

Another thing ... The machines are made in Switzerland, but the
marketing office in Holland holds all the compliance docs. Since
sometime "whenever" the free circulation of goods between member
states has not been regarded as importing and exporting, IE for
customs purposes. But now they seem to be trying to re introduce the
concept of "Importing" goods into the UK from other member states
again. They can't have it both ways.

Similarly the Medical Devices Agency has determined that our machines
are not "Medical Devices". But on the directive document itself in
Annex1 "Medical Devices" is the nearest category applicable, but in
Annex 2 "Medical Devices" are broken down into 10 Sub-Categories, the
first 9 sub-categories are explicit and definitely not applicable, but
the 10th sub category is a "Catch everything else" category so we
can't really avoid it.

Is it a "Medical Device" or is it not ? The MDA says it's not. It's
the EU that came up with all this jargon, can't they just stick with
their own definitions?

AAMOF I notice that of the categories in Annex 1, when expanded into
sub-categories in Annex 2 most have a "Catch everything else" sub
category.

A very strange way to write a law ISTM to have 9 explicit and
precisely described categories, plus one "Catch Everything Else"
category. Eg Purple Sprouting Broccoli is forbidden, Celeriac is
forbidden, Fennel is forbidden, Kohl - Rabi is forbidden, Parsnips
are forbidden, Mangle - Wurzels are forbidden, Oh, and BTW "All other
vegetables are forbidden.

"Done in Brussels" You can say that again. :-(

The document can be found here, the annexes are at the end.

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00240038.pdf


Neither of the scenarios you describe constitute placing the product
onto the market - i.e. you can supply spares and repair.

In the context of the rest of it, to be honest, I would take a
commercial view. The EMC Directive was bad enough. WEEE aspires to be
a shambles.

I think that there are three courses of action

- Take product off of market

- Look at registration and the commercial implications.

- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey.

I don't suppose that actually happened. Given a Hitleresque Trading
Standards Dept 1 or 2 PC suppliers got a 500 quid fine for selling
non-compliant PC's because they'd added a DVD drive and not gone
through all the testing again.

One of my kids came back from the sweetshop with a suwanee whistle
made of sugar candy. It had a sugar piston on a movable rolled 3mm
paper "stick" that came loose after about 15 minutes sucking, and
could easily choke a child. I took it to trading standards and
couldn't get past the reception desk. The receptionist took it
"Upstairs" and came back saying they couldn't do anything because
despite being overtly dangerous it didn't break the food regulations.
I said "How can a food have moving parts? And anyway it's not CE
marked. Ah well that's just a minor labelling violation. The message
being:

*They will choose what issues they will choose to address*

Realistically £5K
is absolute worst case for this. I haven't looked at WEEE in this
regard, but for sure is you are a small business there are much bigger
fish for the jobsworths to fry.

In the Irish republic Boots were fined €13,000 for offering for sale a
battery operated toothbrush, without displaying on the shelf edge
ticket alongside the price the cost of it's de-commisioning. LOL !

If the product isn't that lucrative then certainly take it off the
market, but I wouldn't feel bullied about that.


It's old technology, it's life as a product is limited but at £23,000
a piece the profit on 2 or 3 would be useful.

DG

On 2007-01-29 23:47:28 +0000, Derek Geldard said:

Another thing ... The machines are made in Switzerland, but the
marketing office in Holland holds all the compliance docs. Since
sometime "whenever" the free circulation of goods between member
states has not been regarded as importing and exporting, IE for
customs purposes. But now they seem to be trying to re introduce the
concept of "Importing" goods into the UK from other member states
again. They can't have it both ways.

Hah.

This is probably because of the different policing methods in member
states I suspect.

In the UK it''s generally Trading Standards, whereas AIUI in Germany
it's Customs.

This makes me laugh because the whole point was to avoid national trade
barriers between
Community countries, not to erect them,




- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey.

I don't suppose that actually happened. Given a Hitleresque Trading
Standards Dept 1 or 2 PC suppliers got a 500 quid fine for selling
non-compliant PC's because they'd added a DVD drive and not gone
through all the testing again.

Which basically means that one can take a commercially viable decision to do
nothing.



If the product isn't that lucrative then certainly take it off the
market, but I wouldn't feel bullied about that.


It's old technology, it's life as a product is limited but at £23,000
a piece the profit on 2 or 3 would be useful.

... although perhaps the cost of certification would equal or exceed
said margin?

In message , Derek Geldard
writes
On Mon, 29 Jan 2007 21:25:48 +0000, Andy Hall
wrote:

Thanks for joining the thread.

I've looked at this whole area at many times in the past - originally
in connection with the EMC Directive.

We've been through all that prior to 1996. In fact in 1989 The NHS
insisted we had our product type tested to IEC 601 by TUV in Germany .
We did that, it put up the cost of the product 19% in respect of a
myriad of sticky labels, silk screened legends, changes to manuals and
some changes which really only related to Europe with their reversible
mains plugs, USW, USW, USW.

I do so love "usw"

.... desktop folder for everything I can't find anywhere else to put


--
geoff

On Tue, 30 Jan 2007 20:36:25 GMT, raden wrote:

In message , Derek Geldard
writes
On Mon, 29 Jan 2007 21:25:48 +0000, Andy Hall
wrote:

Thanks for joining the thread.

I've looked at this whole area at many times in the past - originally
in connection with the EMC Directive.

We've been through all that prior to 1996. In fact in 1989 The NHS
insisted we had our product type tested to IEC 601 by TUV in Germany .
We did that, it put up the cost of the product 19% in respect of a
myriad of sticky labels, silk screened legends, changes to manuals and
some changes which really only related to Europe with their reversible
mains plugs, USW, USW, USW.

I do so love "usw"

... desktop folder for everything I can't find anywhere else to put

Dr Beaker (sp) in Thunderbirds wasn't it ?

Much better than the namby pamby poncy effeminate Latin "etc".

Switches to Media Player to restart the Tannhäuser once again

DG

On Jan 29, 9:25 pm, Andy Hall wrote:
- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any time
soon. Look at the financial and other penalties. For example - worst
case with EMC is £5000 and 6 months in the pokey. Realistically £5K
is absolute worst case for this.

You only get the pokey if you ignore instructions to stop or obstruct
the inspectors.

MBQ

In an earlier contribution to this discussion,
wrote:

On Jan 29, 9:25 pm, Andy Hall wrote:
- Ignore the whole thing. Keep going as before. If you are a small
business, it is very unlikely that anything will come your way any
time soon. Look at the financial and other penalties. For example
- worst case with EMC is £5000 and 6 months in the pokey.
Realistically £5K is absolute worst case for this.

You only get the pokey if you ignore instructions to stop or obstruct
the inspectors.

MBQ

And even then, you probably have to join the waiting list! g
--
Cheers,
Roger
______
Email address maintained for newsgroup use only, and not regularly
monitored.. Messages sent to it may not be read for several weeks.
PLEASE REPLY TO NEWSGROUP!

Derek Geldard wrote:

On 2 January 2007 the Waste Electrical and Electronic Equipment
Regulations 2006 come into force. The burden it puts on small
businesses is draconian. Businesses of all sizes have only until until
15 March 2,007 to join an approved Producer Compliance Scheme. Total
cost of the whole compliance package £1 - 2k in annual membership
charges before a single printed circuit board has been recycled.

From what I can see the costs will depend on if you are classed as a
manufacturer / importer or simply a distributor. Costs for the former
are in the range you quote, however for the latter are likely to be less
(although are as yet undefined).

There is no minimum company size; the regulations apply to all
producers whatever their turnover, market share or number of
employees.

And the "tax" is based on the weight fo goods sold, not their value.

For us the cost of doing this is out of proportion to the profit
generated by our equipment sales so we are considering withdrawing our
product from the market. However we will still have a reasonable
business in supplying spare parts and service for machines sold over
the last 20 years. Unfortunately the information on government web
sites appears to have been written by the Bosnian Serbs, and the
commercial sites contradict each other, are sometimes out and out
wrong and can not be regarded as impartial.

It's a criminal offence not to register before 15th of March, so ...

Another few years of this and the country will be full to busting with
criminals... and most of them won't even realise it.

Is repairing a 12 year old machine using new spare parts "Putting a
product onto the market", thus requiring registration ?

I probably depends on if the parts are classed as "WEEE"... so a
replacement gearbox no; psu yes.

Is selling new spare parts for a customer to repair his 12 year old
machine "Putting a product onto the market".

I don't know, although it seems sales to end users seem to attract less
paperwork complexity than sales to business.

--
Cheers,

John.

/================================================== ===============\
| Internode Ltd - http://www.internode.co.uk |
|-----------------------------------------------------------------|
| John Rumm - john(at)internode(dot)co(dot)uk |
\================================================= ================/

On Mon, 29 Jan 2007 23:19:59 +0000, John Rumm
wrote:

Derek Geldard wrote:

It's a criminal offence not to register before 15th of March, so ...

Another few years of this and the country will be full to busting with
criminals... and most of them won't even realise it.

It doesn't really matter. All the prisons are full, so this guvmint
will just polygraph everybody, then lose all the records...

--
Frank Erskine
You will pay for your sins. If you have already paid, please disregard
this message.

John Rumm wrote:

I probably depends on if the parts are classed as "WEEE"... so a
replacement gearbox no; psu yes.

There are many grey areas in WEEE, but that's not one of them.
Obligations apply only to complete equipment and not to components or
spare parts of any kind. (AIUI, IANAL, etc.)

--
Andy

On Mon, 29 Jan 2007 23:19:59 +0000, John Rumm
wrote:


There is no minimum company size; the regulations apply to all
producers whatever their turnover, market share or number of
employees.

And the "tax" is based on the weight fo goods sold, not their value.

It so happens that our machines are very heavy 425kg but contain
relatively little electical / electronic content, say 25 Kg. Whilst we
don't know what the per tonne charge will be it looks like we would be
hit with a very heavy cost. Afaik you can't break out the electronics
bit yourself and dispose of the rest as scrap metal, the PCS has to
collect and transport the waste in a licensed vehicle. I can't see how
this will work out as it has cost us in the past £1,100 to get a
machine *into* a customer's dept. (Placed by quality assured
installation contractors). 8-(

It also appears that we are obliged to remove and dispose of a
redundant competitors machine if we sell a new one of our own.

That would put the tin hat on it.

This site has more details than most :

http://www.weeecare.com/

There's also an additional charge of £200 + quid that goes to the
environment agency.

No doubt the £6.00/tonne refers to the most easy to process homogenous
waste in full truckloads very close to the depot.

All in all not a very encouraging prospect.

Just as well we sold no "WEEE" in 2006 ...

and I took my pension as of last Friday. :-))

DG