Waste Electrical and Electronic Equipment Directive

The Waste Electrical and Electronic Equipment Directive
(WEEE Directive)is the European Community directive 2002/96/EC on waste electrical and electronic equipment which, together with the RoHS Directive 2002/95/EC, became European Law in February 2003, setting collection, recycling and recovery targets for all types of electrical goods.

The directive imposes the responsibility for the disposal of waste electrical and electronic equipment (WEEE) on the manufacturers of such equipment. Manufacturers are then required to establish an infrastructure for collecting WEEE. Also, we are compelled to use the collected waste in an ecologicalfriendly manner, either by ecological disposal or by reuse/refurbishment of the collected WEEE.

The directive takes effect in the UK from 1st July 2007. From this date onwards, the manufacturers of all photocopiers, printers, multi-functional printers, computers, etc, etc, are required to arrange the environmentally friendly disposal of all such equipment made by them which reaches ?end of life? - i.e. is no longer required by the owner and would otherwise be discarded as waste.

What are the supplier?s responsibilities?
The key to determining the liability on the manufacturer is the existence ? or not ? of the image of a wheelie-bin, crossed out, on the product concerned. Manufacturers were required so to label their products from August 2005, and this label determines that the manufacturer is required to remove such ?end of life? products (so called ?New WEEE? if such a label exists) if the owner so requests. Should the owner wish to continue using the product or to sell it privately to another person or organisation, it has clearly not reached the end of its life.

Within the ?photocopier? (MFP) industry, which operates within a largely saturated and replacement market, most sales of our products are ones where one device replaces another. Often, the manufacturers are different, if the customer chooses to change the brand of the product used. This has resulted in an arrangement whereby the various manufacturers have agreed to cooperate in the removal of WEEE and to arrange for the appropriate recycling of the device concerned. If the product was supplied by a dealer, rather than by the manufacturer?s own sales and service force, the liability remains with the manufacturer, unless the respective dealer has agreed with his supplying manufacturer to take on the liability himself for end of life products replaced by a product he has sold. The manufacturer then has passed the liability to that dealer, who needs to operate in cooperation with a licensed recycler.

What if there is no crossed out wheelie-bin? (?Old WEEE?)
The obligations on the manufacturer are similar, inasmuch as, if the customer wishes the manufacturer to remove the product, the manufacturer is required to do so, if he has supplied a similar product to replace it ? but only if this is the case. This is the limit of the obligation on the Producer in the case of ?Old WEEE?

Who is the owner?
It is important to be clear who the owner is. It is often the case that such products were acquired on a lease, in which case the title to the product remains at all times with the leasing or finance company, and never resides with the user. It is therefore clear that the decision as to whether the device has reached ?end of life? is one to be made by the leasing company, not the user/customer.

What is the impact on the purchaser of a replacement/new MFP?
Little. If the purchaser is the owner of the previous product, simply to decide whether the product is to be retained, or to be removed. If to be removed, who is the owner? Only the owner can decide if end of life has been reached, and the product therefore to be recycled. However, each user/owner of a machine he no longer requires is responsible for removing any sensitive information that may reside in the machine?s memories before the machine is removed.

What will Konica Minolta do?
We have entered into arrangements with appropriately licensed recycling companies to facilitate the optimised retrieval of recyclable content from, and environmental friendly disposal of, the materials and components of our products which reach end of life, and also of the many competitor products which we upgrade to Konica Minolta. We are a Registered Producer under the terms of the legislation; our Registration Numbers are WEE/JH0052TQ and WEE/JJOO52TQ. Customers can be assured that not only do we fully adhere to the requirements of the Directive, but also seek to exceed its requirements in any way possible that further protects the environment.

Konica Minolta / Marketing July 2007

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