The Register does not answer any content-related questions about the Dutch implementation of the WEEE Directive. The Government has set up a specialist desk for this purpose, called Waste Information Helpdesk. The Register has compiled the following FAQs in consultation with this desk.

1. Am I a producer and must I register?


Yes, as a producer of EEE you must register. The definition of a producer is specified in Article 1.p of the Dutch implementation of the WEEE Directive. Webshops also fall under this definition. For retailers and importers, the following rule of thumb applies: If the invoice from the supplier of electrical appliances and low-energy light bulbs (EEE) specifies a VAT zero rate or a foreign (not Dutch) VAT rate, then you are the producer unless that supplier has voluntarily transferred its responsibility to a Dutch legal or natural person by means of a mandate in accordance with Article 21. If you are already a member of a producer collective or to a collective system, you do not need to do anything because those organisations will take care of the registration and the reporting for you. Producers that individually meet their obligations in the WEEE Directive can register on the page for producers.

2. Am I a treatment operator and must I register?


Yes, as an operator or exporter you must register. A treatment operator is a company that converts or processes discarded electrical appliances and low-energy light bulbs (WEEE) in the Netherlands or exports them abroad to be processed. As an exporting trader you are therefore also a treatment operator that must report collection and (material) recycling. WEEE that is collected by an individual producer or a collective system in the Netherlands and is processed at your premises does not need to be reported: the producer or collective system will do that. In addition, stocks of electronics (from producers) that are destroyed do not need to be reported because they were never put on the market in the first place. Treatment operators can now already register on the page for treatment operators

3. What does registration cost?

For treatment operators registration is free. The producers pay for the costs of the Nationaal (W)EEE Register. Producers that registered individually will receive an invoice from the register of maximum €175,- per yearThe rate for reporting year 2019 is set at € 100 per producer per year; the rate for reporting year 2020 will be announced shortly. For producers that are affiliated to a producer collective the costs will be payed and cleared by the collective.

4. Which appliances fall within the scope of the WEEE Directive?

Note! As of 15 August 2018, changes regarding the scope of the Dutch WEEE Directive will enter into force. There will be extra products which will fall under the scope of the arrangement and various products will fall outside of the scope. The National (W)EEE Register does not make any statements about whether products fall within or outside the scope of the regulation. For questions, please contact the Helpdesk Afvalbeheer.


Please inform the Handreiking reikwijdte (Dutch). This is a Dutch tool to decide which appliances fall under the concept ‘electrical and electronic equipment’ as mentioned in the Dutch implementation of the WEEE Directive in Article 1.f. Some specific appliances are mentioned in chapter 3 of the Frequently asked Questions WEEE Directive.

 

5. How can a Dutch producer meet its obligations?

A producer can arrange to meet its obligations individually or become a member of a producer collective or a collective system. In practice, this means that the producer pays the collective for a system of collection and treatment. The collective also registers at the National (W)EEE Register on behalf of this producer. The producer still bears responsibility, however, but by joining the collective it is showing that it is fulfilling that responsibility. The collective systems are:
PV Cycle
Stichting RTA
Wecycle
WEEE Nederland

6. Authorized representative for foreign producers

This producer can authorise a legal or natural person in the Netherlands (Article 21  Dutch implementation of the WEEE Directive) to meet the obligations issuing from the regulation on its behalf. That means to register and indicate how the producer is meeting its collection obligation. From then on, the authorised representative is responsible for fulfilling the producer’s obligations. The authorised representative can become a member of a producer collective or a collective system.

7. Which obligations do treatment operators have?

If you are a treatment operator of discarded electrical appliances and low-energy light bulbs (WEEE), you are obliged to:
- Arrange for the proper treatment of all the WEEE collected separately in accordance with the best available technologies. By proper treatment is meant:
* compliance with selective treatment for operators that collect/process (Appendix VII of the WEEE Directive)
* achieving targets for recovery (Appendix V of the WEEE Directive)
* treatment in accordance with the Cenelec treatment standard
- Report to the National (W)EEE Register every year before 1 May, stating the amount of WEEE treated by you in the previous calendar year and the achieved target figures for (material) recycling & recovery.

 

8. Implementation of changes reporting categories WEEE.

From 15 August 2018 several changes in the scope of the WEEE directive and its Dutch implementation (Regeling AEEA) were set in force. However, in order to keep the report clear and comparable, it was decided in consultation with the Ministry of Infrastructure and Water Management that the corresponding change in reporting categories will only be applied from 1 January 2019.

In this document it is indicated in which categories producers, importers and recyclers must report to the National (W)EEE Register as of 2019. The document has been agreed with the Ministry of Infrastructure and Water Management.

Questions about the WEEE Directive?

The Register does not answer any content-related questions about the WEEE Directive other than the questions included in the FAQs. The Government has set up a specialist desk for this purpose, called Waste Information Desk.