Since August 15, 2018, there has been a legal amendment to the scope of the Dutch Regulation on Waste Electrical and Electronic Equipment (hereafter: the Regulation). This amendment to the law has (possibly) an impact on the electrical appliances you are legally obliged to report. We call this the Open Scope with three types of changes:
Before 15 August 2018, only products that were dependent on electricity for their primary function (via mains or battery) fell within the scope of the Regulation. From August 15, 2018, also products with an electrical function that does not have to do with the primary function of the product fall within the scope of the Regulations. Examples:
A number of new exceptions are in force. This means that some products no longer fall within the scope of the Regulation and no longer need to be reported. You will find an overview of these new exceptions below:
Wecycle has drawn up an overview with a few examples per exception. You can also find examples of products on which a particular exception does not apply.
Based on the above information and the information in the overview it cannot always be concluded a product does not have to be reported. We request you to contact us in case of doubt. If necessary, we ask the helpdesk of the Dutch government to determine whether or not an exception applies to your product.
The government has drawn up the following guideline to determine whether the device must be reported completely or only the electrical component. Please, pay particular attention to the underlined sections.
If an electrical or electronic element is dismountable/replaceable of a product that functions both electrically and non-electrically (the product still works after removal of the electrical element), only the removable electrical or electronic element of the product can be regarded as a device and not the entire product. An element is considered as dismountable and replaceable if the user can remove it in a simple manner (i.e. manually or with standard tools) without damaging the product in which the electronics are incorporated.
If the above applies to your product you only need to report the electrical element. If the above does not apply to your (electrical) product, you need to report the entire device.
From January 1, 2019 we will switch from ten to six categories. The old categories have been reclassified into six new categories. You will find the old and new categories below:
If you report once a year, you make use of the new categorization and associated article codes at the beginning of 2020, when you submit your annual report of 2019.
If you report quarterly, you make use of the new categorization and associated article code on the 1st of April 2019, when you submit your report of the first quarter of 2019.
New in 2019 is that several products must be divided into categories based on the external dimension. This division is applicable for the following type of products:
This division is not applicable to luminaires. For luminaires a distinction is made based on weight (> 750 grams or ≤ 750 grams). Both divisions are applied clearly in the products and tariff list 2019.
When determining the size of your device, do not include the length of the cable. If your company sells separate cables (with or without plug), measure the size of the coiled cable. Further explanation can be found in the document 'Determine device size'.