WEEE Ireland, The Irish Compliance Scheme for Electrical and Battery Recycling

WEEE stands for Waste Electrical and Electronic Equipment. Waste batteries and WEEE contain metals and other elements that can be recovered and used again in production.

WEEE Ireland is a not for profit organisation set up by industry to provide collection and recycling facilities to enable B2C member producers to meet their obligations under the WEEE and battery regulations. Membership is renewable annually.

Businesses at the top of the supply chain in Ireland for EEE and Batteries (also known as a “Producer”).

Under the regulations, a Producer is anybody that:

a) Manufactures in the state or imports from outside the state on a professional basis, batteries or any products operated by batteries or mains power.
b) Is established in another Member State or third country, but sells electrical and/or electronic equipment (EEE) by means of distance communication directly to private households and/or other users in separate Member States.

All producers must register with the National Producer Registration Body.

• Registering with the Producer Register Limited, and Membership of a Compliance Scheme (if applicable).
• Holding a Certificate of Registration, and Certificate of Membership of a Compliance Scheme where applicable.
• Reporting placed on the market (POM) data to the Blackbox each month.
• Financing the future management and recycling of material at end of life.
• Providing take-back and recycling information to the end user.
• Product Marking (Crossed out wheelie bin, CE, RoHS)
• RoHS conformity.
• Internet Sellers also have some additional obligations, see here »

The NPRB is the national registration body for all WEEE or battery producers and is known as the Producer Register Ltd. Both B2C and B2B producers must register with the NPRB. Following registration, producers will receive log on details for the Black Box (see section 5). Membership is renewable annually. Click here to visit the Producer Register website »

The regulations require that the registration number including alpha indicators issued by the NPRB must be displayed on all invoices, credit notes and delivery documentation. The number also needs to be included on your website should you have one and trade on it.

An Authorised Representative for our members (where applicable) is any natural or legal person established within the Republic of Ireland who has been appointed by written mandate from a Producer based outside of the Republic of Ireland, to fulfil that Producer’s obligations as required in the Irish State for the placement of EEE onto the Irish market.

If an EEE product placed on the Irish market, can at any stage be sold to or used by a consumer, this transaction is considered B2C, regardless of the supply chain (e.g. from producer to a wholesaler/retailer etc…). By industry agreement all Lighting products in scope are reported as B2C to the Black Box.

If the end user of an EEE product placed on the Irish market is a commercial organisation this is considered as B2B. By industry agreement all Lighting products in scope are reported as B2C to the Black Box.

Waste from EEE likely to be used by both private households and users other than private households shall in any event be considered to be WEEE from private households (B2C).

As a B2C producer you must register annually with both the NPRB and WEEE Ireland in order to facilitate your WEEE and battery take-back obligations.

As a B2B producer you are required to prepare 3 year waste management plans and annual waste management reports. Waste management plans are submitted to both the NPRB and the Environmental Protection Agency (EPA). Waste management reports must be submitted to the EPA.

Yes, registration as a retailer is a separate process to that of a Producer. You can register with your local county council at an annual charge of €200 or you can register with WEEE Ireland for free by clicking here: Retailer Registration »

The Black Box is a confidential online data submission tool. Under the regulations producers are required to submit monthly reports on the units and weights of EEE, and the chemistry and weights of batteries, which they have placed on the Irish market. Access to Black Box is granted following NPRB registration. Black Box only provides WEEE Ireland with monthly invoicing information on individual members and cannot disclose market share or other commercially sensitive data with anyone – including WEEE Ireland.

The Black Box closes for submissions usually on the 19th of each month - before that date producers are required to submit their data for the previous month, e.g. for April, the information would require reporting by May 19th.

Any electrical, electronic or battery operated products including batteries that you import or purchase from an unregistered local supplier requires reporting. Using the category listings issued by the NPRB (currently version 5.7), you select the relevant products that are in scope of the regulations and their reporting categories.

Should you require any clarification on if a particular products falls under the scope, you can contact the National Producer Registration Body for assistance at 01 5522606, or on info@producerregister.ie

a) Any EEE or batteries supplied by another Irish producer/distributor registered or part of a registered supply chain. You can check a producer’s status on: www.producerregister.ie
b) Any EEE or batteries you are exporting directly from ROI. Proof of export will need to be retained.

For EEE you need to know the sales of relevant products by:

• WEEE category
• Sub category
• Quantity
• Weight
• Channel (B2C/B2B)

* The data highlighted in red is what will be input to the Blackbox. This information should be filed in hard copy as it is part of your audit trail and should be traceable by product code through your sales invoicing system and back to your purchasing system also.

Batteries are reported by Type, Chemistry and Weight.

It is extremely important that full and accurate reporting of net weight by product category is made to the Black Box each month. As of the 26/09/08, product weight must include any accessories supplied with it, but must exclude any packaging, instructions for use and incorporated/embedded batteries. The weight of batteries incorporated in products must be deducted from the product weight before the product weight is reported to the Black Box.

As of the 26/09/08 battery weights, excluding packaging, are reported separately to the Black Box under the appropriate chemistry classification in category 11. (Prior to 26/09/08 battery weights were included in the product weight.)

Products including those under warranty returned by your customers should be deducted from Black Box reports provided that they can be resold and reported again, or that they will be exported back to a supplier abroad (incl Northern Ireland). Proof of shipment will need to be retained. Guiding principle is if products are to be recycled in Ireland then details remain on the Black Box. If warranty products are being shipped abroad then details are deducted from the Black Box.

If you have any difficulties with reporting to the Blackbox you can contact the Blackbox technician for assistance on + 353 (01) 417 2228, or at weeeblackbox@deloitte.ie

If your supplier is registered with the Producer Register, then you do not need to double report the same products. If however your supplier is not registered, you will need to report the products to the Blackbox yourself.

These are recycling charges authorised by the government for certain categories of B2C electrical and electronic products. They are referred to as visible Environmental Management Costs (vEMC’s). These fees are invoiced by producers to retailers/distributors. The fee must be shown separately for each product line to which it applies. vEMC‘s should not be charged on products being exported. Retailers/distributors then show and charge these to end users on a per product basis. The applicable fees are shown in the latest NPRB category listing (currently 5.7).
WEEE Ireland charges its member companies these fees based on the numbers of units reported to the Black Box. Visible fees were re-introduced with effect from 01/07/2014.

These are scheme recycling charges for all B2C products and any batteries reported to the Black Box. These charges apply even where a visible fee is charged. These are referred to as Recycling Management Costs (RMC’s). For most categories the charge is weight based but for lamp categories lamps 5.1 and 5.2 and smoke detectors with ionisation chambers, cat 9.1, they are charged on a per unit basis. It is not permitted to show these costs anywhere in the supply chain. These charges were introduced effective from 01/03/2011.

As a producer you are required to have access to data to prove that the products you are importing and placing on the market comply with the tolerances for certain restricted substances. S.I. 349 of 2014 requires you to have access at all times, at an address within the State, to records of certification of compliance to, or laboratory test reports demonstrating compliance with the regulations. This information must be available for 6 years from the end of the year the product was placed on the market. For further information please click here »

(i) the requirement not to dispose of waste electrical and electronic equipment in their normal municipal waste bin and to have such waste collected or disposed of separately or taken back on a like for like basis,

(ii) their role in contributing to re-use, recycling and other forms of recovery of waste electrical and electronic equipment,

(iii) the return and collection systems available to them,

(iv) the potential effects on the environment and human health as a result of the presence of hazardous substances in electrical and electronic equipment, and

(i) The potential effects on the environment and human health of the substances used in batteries.

(ii) The desirability of not disposing of waste batteries as unsorted municipal waste and of participating in their separate collection so as to facilitate treatment and recycling.

(iii) Their role in contributing to the recycling of waste batteries.

(iv) The meaning of the symbol of the crossed-out wheeled bin shown in the Fifth Schedule and the chemical symbols Hg, Cd and Pb.

(v) How to safely remove a battery from an appliance where a battery is incorporated into the appliance concerned.

(vi) Where appropriate, the type of any battery that is incorporated into an appliance.