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Posted By Dave Stevenson
Hi everyone,
I’ve just started with a large US clothing retail company, who are stopping a potentially large shipment of soft toys because they contain button batteries which when touched make a noise, and thus may come under the requirements of WEEE. Concern is raised from the US regarding the costs of WEEE obligations and as a new consultation is imminent they are holding the shipment (as the producer pays after 15th Aug 2005). Prior to my arrival they have sought legal advice from across the globe and have spoken with the DTI and it is reported that no-one could confirm if this is WEEE or not.
I’ve not dealt with environmental compliance before as I’m a CS&HP, but common sense and a couple of hours on the internet has led me to believe that these products would not be considered WEEE because products that have ‘electronic or electrical components that are not needed to perform their primary function’ are not covered by WEEE.(such as musical greetings cards) I believe this toy would fall into this category.
I’ve also been asked about ROHS, and having reviewed this requirement I believe it is highly unlikely that this toy would fall under this legislation.
So as ‘environmental compliance’ is buried deep into my job description as H&S Manager, the UK team, including legal are looking to me for a decision next week, despite my bests efforts highlighting the fact that WEEE may not even be enforce now until Jan 2007 and even if it did, and this toy did fall under WEEE (very unlikely in my opinion), the probability of customers returning these toys is very remote under WEEE and the commercial risk is very small.
Follwoing my stance, you would not believe the emails flying in from the US following my interpretation above regarding this issue, and I believe they are blowing this completely out of proportion (in my opinion).
Anyone have any advice?
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Rank: Guest
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Posted By TBC
This sounds typical American - panic stations at what they know nothing about. I used to work for some - it didn't last. Their thoughts on H&S didn't match their actions.
Anyway I like the DTI Summary:
Summary of the WEEE and RoHS Directives
The Waste Electrical and Electronic Equipment (WEEE) Directive was agreed on 13 February 2003, along with the related Directive on Restrictions of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS).
The Waste Electrical and Electronic Equipment Directive (WEEE) aims to minimise the impacts of electrical and electronic equipment on the environment during their life times and when they become waste. It applies to a huge spectrum of products. It encourages and sets criteria for the collection, treatment, recycling and recovery of waste electrical and electronic equipment. It makes producers responsible for financing most of these activities (producer responsibility). Private householders are to be able to return WEEE without charge.
The RoHS Directive will ban the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants from 1 July 2006. There are a number of exempted applications for these substances. RoHS takes its scope broadly from the WEEE Directive. Manufacturers will need to ensure that their products - and their components - comply in order to stay on the Single Market. If they do not, they will need to redesign products.
In my opinion we are talking about big items like computers, white goods and cars etc when we consider WEEE and ROHS not little cuddly toys. It would not be cost effective for anyone to think about recyling the components of a cuddly toy. Perhaps a bit of instruction on how to dispose of the item sensibly would suffice.
Regards
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Rank: Guest
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Posted By TBC
Forgot to mention when they talk of Cat7 (toys and sports goods) they will have the bigger items in mind. Things like battery operated cars (the sit in ones and workout machines) sometimes with big batteries and lots of bits for recycling, which can be taken to local waste amenity collection points.
Have you seen this site?
http://www.dti.gov.uk/su...WEEE_and_RoHS_Directives
and if you look on the site below and search for 'button' it will give you more info
http://europa.eu.int/eur...003/com2003_0723en01.pdf
Good luck
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Rank: Guest
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Posted By Dave Stevenson
Many thanks,
I'm glad I'm not going mad on this one. Common sense prevails!
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