Apologies to all for false information on my recent submission.
The DTI have done the dirty on me! The current draft WEEE document looks
identical
to the version that I downloaded some time ago. It has the same numbers
and dates etc. on the front page and I assumed (foolishly) that it was
unchanged.
However, investigation showed that although the text of the main body
appears to be unchanged, it has been modified to print out on more pages
– what an example of minimising resources! It has also added the extra
Annexes.
My interpretation of the reference to ALL items in section 1 of Annex II
is to question the term "separately collected WEEE". Sections 15 & 16 of
the "Whereas" at the commencement of the draft indicate this to be items
collected separate from general household waste. Considering the
reference to Article 4 of directive 75/442/EEC. This details measures "to
ensure that waste is recovered or disposed of without endangering human
health and without using processes or methods which could harm the
environment, and in particular:
without risk to water, air, soil and plants and animals,
without causing a nuisance through noise or odours,
without adversely affecting the countryside or places of special
interest.
Member States shall also take the necessary measures to prohibit the
abandonment, dumping or uncontrolled disposal of waste."
So the question seems to be "how are you going to dispose of the product
at its end of life?" If dangerous substances are involved in some
components (as per RHoS), then they must be dealt with accordingly.
Anyone with further thoughts?
Regards,
Neil Helsby
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