But despite the understandable fears of increased costs and complexity for manufacturers and dealers, the new environmental law provides the industry with an opportunity to show its green credentials, says Paul James of DHL's Environmental Compliance Solutions.  The WEEE Directive was developed by the EU as a way of ensuring that producers of electrical and electronic equipment pay for the sound management of their products when they come to the end of their useful lives.

As with most directives that come from committee rooms in Brussels, the realities of enacting the proposed legislation took far longer and have been much more complicated than anticipated. It is no surprise to learn that while the Germans, Irish and Dutch introduced the new legislation months, even years before the UK, we were one of the last countries to sort out how the directive will be introduced into national law. After several false starts and public consultations, the regulations finally came fully into force in July 2007. 

While most manufacturers of vending machines and associated products have understood the new legislation and planned well to discharge their responsibilities, many distributors and agents are still unclear about their role with regard to WEEE and what steps they need to take to ensure they don't fall foul of the law. 

In simple terms, the directive says that it is the ‘producer' of the product that is responsible for paying for the collection and recycling of items covered by the directive. But be careful, as the definition of a producer is defined as any business that places the electrical product on the market in the UK. If the product is made in the UK, then it will be the original manufacturer who is responsible. If imported, then the importer of record, regardless of the brand of the product, will be obligated. Clearly, this is where distributors of machines need to pick up the ‘WEEE tab'.

Any product that requires electricity to perform its primary function and falls into one of ten categories of electronic and electrical equipment (EEE) - including automatic dispensers, medical devices, IT equipment, consumer goods, toys, sports equipment and power tools - will be covered by the regulations. And whilst many products will fit easily within this category structure there are inevitably many products where it is not so clear cut. 

There are a number of important exceptions, such as plant/machinery,  military equipment and products rated at more than 1,000 volts AC or 1,500 volts DC. Certainly, vending equipment that uses electricity to promote, dispense and vend drinks, foodstuffs or non perishable items are caught by the WEEE directive.

Having clarified that distributors and agents are likely to be obligated under the WEEE regulations, what are the main issues that need to be considered? Even more pertinent is the question: how can I turn another raft of potentially expensive legislation into an opportunity for my company?

Setting up the systems: For many obligated companies, one of the first issues that needs to be addressed is the potentially difficult task of calculating and reporting the amount of EEE placed on the market. At first glance reporting sales by both units and weight should be reasonably straight forward, but these figures have to be reported separately for sales to consumers and sales to businesses. 

Given the increasing crossover between business and consumer products for some producers this will be no easy task. And depending on the involvement a producer might have with the manufacture of their branded or imported products, obtaining weight information may be another time consuming diversion.

Whilst sales statistics can be extracted from finance systems, many producers are turning to specialist businesses with product weight databases to calculate the tonnage that their sales represent. Calculating the weight and determining the EEE category of products can turn into a huge task for businesses with numerous product lines. Outsourcing this function to experts that already have market information and established systems can often make sound economic sense.

Collection systems

Whilst consumer products will in the main be returned through local authority collection sites (and a producer's collection responsibility via their scheme calculated as a percentage of what has been discarded based on their sales in that year by EEE category) the practicalities of establishing and managing a collection system for business products lies with the producer. 

Adding brand value

The WEEE Directive, like all business challenges provides progressive companies with an opportunity to differentiate themselves from their competition.

Handling the practical collection of products in an unprofessional way could have a negative impact on the image of your business, as this type of activity is clearly a key customer-facing ‘moment of truth'. Conversely, getting this activity right, providing a high level of customer service and ensuring customers understand the processes in place which ensure that used products are recycled responsibly, can pay huge dividends to your business' reputation.

Scare stories of irresponsibly recycled goods ending up in third world countries, where untold environmental damage has occurred, could come back to bite your business if WEEE is not managed properly.

Choosing a partner

Like any supply chain, the complete solution where WEEE is concerned, is only as good as the weakest link in the chain. If you have appointed a WEEE partner on the basis of cost alone and not service levels and experience, you could live to regret that decision. The decision to appoint a WEEE partner is far from simple, it's always important to remember that you are handing over part of your brand equity to this partner - so choosing someone with a strong brand of their own to defend and with a strong track record of customer service would be a good first step in the selection process.

Minimising transport costs

There has been little mention in many articles so far of the cost of implementing WEEE from a logistics perspective. Studies conducted so far indicate that as much as 60% of WEEE costs will come from the physical movement of goods. Clearly, the practical logistical costs of implementing WEEE will be significant. Again, businesses need to think about the selection of a WEEE partner that understands the often misunderstood skill of ‘reverse logistics', which seeks to utilise supply chain efficiencies to transport returned products.

In most instances, the ability to offer timely and cost-effective reverse logistics solutions is based on the density of the logistics provider's network and its ability to gain maximum efficiencies from its fleet. The bigger and more diverse the fleet - and the organisation's ability to manage this resource - then the higher will be the likelihood of reduced WEEE transport costs.

Getting value from waste products

There is a growing UK market for the recycling and re-use of electrical and electronic products. Being able to ‘plug into' this emerging market can not only reduce your WEEE costs, but actually generate revenue in certain instances.

Establishing links with a WEEE compliance scheme that has strong relationships right the way through the waste supply chain is another key decision that could transform the way your business deals with its environmental obligation. 

Clearly, there is a lot more to the WEEE Directive than simply registering your business with an approved compliance scheme and hoping it all goes well. So far the Environment Agency has been soft on businesses that have not registered, despite a clear obligation. Such a ‘light touch' approach is not likely to last for much longer, with the authorities sharpening their teeth and looking to actively prosecute companies that are not adhering to WEEE.

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