The WEEE Directive has quite a lot to say about collection/take-back obligations for sales to “consumers”, and a business seller cannot offload those costs onto a consumer (not directly at the time of disposal anyway, though it’s presumably going to get build into the product cost somewhere along the line). A B2B transaction is, of course, not such a sale, so it is legal to specify in the contract who takes responsibility for WEEE disposal, and it’s not that uncommon for it to be placed onto the buying business.
That said, some WEEE is quite valuable these days, and some waste processors may be quite keen to take it off your hands. And as has already been said, the requirement to join a Producer Compliance Scheme arises when the EEE is produced, so the cost of the PCS bit is unaffected by the eventual disposal route. John. ________________________________ From: Carl Newton [mailto:[email protected]] Sent: 08 October 2010 19:51 To: [email protected] Subject: [PSES] B2B WEEE - Transfer of responsibility List members, I've come across a slant on B2B WEEE compliance that I was not aware of and I would like to know if any of you have experience with this approach. A UK distributor approached a WEEE PCS company and was told that in cases of B2B, it is legal to transfer the responsibility for disposal of EEE to the customer, including costs. I've seen the 'Terms and Conditions' for a German IVD device in which this is spelled out in detailed legalese. Safety in numbers. Is this common practice? Thanks in advance, Carl - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
