EA publishes new guidance on WEEE definitions

The EA said that it aims for the guidance – titled “When electrical and electronic equipment (EEE) becomes waste (WEEE)” –  to help the sector decide when they are dealing with EEE and when they are dealing with WEEE.  

The guidance states the following regarding the respective definitions:  

EEE means equipment which is dependent on electric currents or electromagnetic fields to work properly. 

EEE also means equipment for the generation, transfer and measurement of such currents and fields, designed for use with a voltage rating not exceeding: 

• 1,000 volts for alternating current 

• 1,500 volts for direct current 

WEEE means electrical or electronic equipment which is ‘waste’ within the meaning of Article 3(1) of the Waste Framework Directive as read with Articles 5 (by-products) and 6 (end of waste) of that Directive. Therefore, any EEE which the holder discards, intends to discard, or is required to discard, is ‘waste’. This includes all components, subassemblies and consumables which are part of the item at the time it is discarded. 

Also this week, the EA announced that all WEEE will be notifiable under new codes from 1 January 2025.

Issues with the guidance 

Craig Anderson, CEO of the Reuse Network, commented on two issues he has found with the guidance:  

1. The first is the expectation implied that the original owner passing on or donating the item is aware that it only needs a “minor” repair to be usable again. How can we expect the first owner to have the expertise to know that only minor repair is required? It may look ok, but no-one knows the extent of repair required until a trained technician opens it up – and that includes the driver collecting the item. 
2. Any EEE you deem irreparable but wish to salvage parts for further reuse in other similar products – the parts become WEEE. If during repair or refurbishment the holder decides an item of EEE is not suitable for its current use and dismantles it into its different components, then the EEE has been discarded and so becomes WEEE. The dismantled components that are removed from an item of WEEE are waste. To reuse these components, for example to refurbish another item of EEE, the components must meet the end of waste requirements. 

He added: “To us at Reuse Network we say this is unworkable and will impact not just Reusers, but all those appliance and tech repairers in the private sector.  

“Just because the Reuse Network membership wishes to comply with such regulations, does not mean we should be at a disadvantage to other EEE product repair sectors.  

“If salvaged parts from electrical equipment are deemed waste, then so should any salvaged part from any product therefore be deemed ‘waste’ – including, big-brand forecourts, OEM refurbishment operators, salvage yards and IT asset companies to name but a few. 

“Reuse is not about waste, it’s about the consumer (in our case the low-income consumer), and we desperately need to deflect waste policy interventions that stifle our reuse and repair sector to ensure quality reused and second-hand goods are supplied to people in crisis in the UK.” 

The Reuse Network works with over 150 reuse charities and commercial partners with the aim of alleviating furniture poverty.