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WEEE producer : Who is considered to be a WEEE producer?

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Why are some companies considered WEEE producers?

Electronic recycling cycle

Are you a Producer?

Do you put product on the Spanish Market through an import? Do you manufacture Electrical or Electronic Equipment (EEE) in Spain? Even though your company manufactures in another country, do you have a headquarters in Spain that is in charge of sales and distribution? Does another company manufacture your products by putting your brand on it? Do you sell products in Spain online?

If the answer to any of these questions is YES, you are a "PRODUCER OF ELECTRICAL OR ELECTRONIC EQUIPMENT (EEE) " and you should know how RD 110/2015 affects you:
 

Who is a WEEE Producer?

Royal Decree 110/2015 of 25 February on Electrical and Electronic Appliances, Article 3, establishes WEEE PRODUCER status for any natural or legal person who, regardless of the sales technique used per Law 7/1996, of 15 January, on the Regulation of Retail Trade distance contracts:
 
  • Is established in Spain and manufactures EEE under their own name or brand, or designs or manufactures and markets them under said name or brand in Spanish territory.
  • Is established in Spain and resells products manufactured by third parties under its own EEE name or brand name, without the seller being considered a "producer", if their brand appears on the appliance, in accordance with paragraph 1.
  • Is established in Spain and professionally engaged in putting EEE from third countries or another member state on the Spanish market.
  • Sells EEE by means of distance communication, directly to private households or professional users in Spain, and is established in another member state or in a third country.

Who is a Battery Producer?

Royal Decree 710/2015 on Batteries and Accumulators, Article 3 establishes that any natural or legal person has the status of PRODUCER of batteries and accumulators who, regardless of the sales technique used, places batteries or accumulators on the market for the first time, including those that are part of appliances or vehicles, in the context of a professional activity.
 

Quarterly Communication

Before the 20th day of the month following the previous quarter, the quantities of WEEE and/or batteries and accumulators placed on the market during the previous quarter (units and Kilos) are communicated.

The data is entered into www.sunreuse.eu. using the new INTRANET, which is intuitive, easy to use and has a personalised space for each producer.

SUNREUSE ensures that this information is transmitted to the ministry, as required by the regulations.

At the end of the process the production company receives an invoice based on the number of appliances put on the market and the rates (WEEE rate) determined between SCRAP and the company.

The company must thereby pay the invoice on a quarterly basis, which is calculated by multiplying the tarif or WEEE Rate by the number of kilos or units put on the market by the company.
 

Other Obligations

  • Producers are to be associated with Collective Extended Producer Responsibility (SCRAP) Systems for Waste Electrical and Electronic Equipment (WEEE) in order to fulfil their obligations.
  • They are to register with the RII-AEE (Integrated Industrial Register for Electrical and Electronic Equipment Producers) and update any information that may change. (SUNREUSE WILL BE RESPONSIBLE FOR THIS OBLIGATION AT THE TIME OF ADHESION).
  • Quarterly COMMUNICATION: Send the data for the products placed on the market quarterly, in units and kilos.
  • Marking with the crossed-out container symbol.
Producers are to mark EEE put on the market with the proper symbol in order to maximise the collection of properly separated WEEE. This symbol is to be displayed visibly, permanently, and legibly on each device. In special cases, if required by the size or function of the product, the symbol can be affixed to the packaging, the instructions for use, and the EEE guarantee.

Producers of EEE are to specify by means of a mark on the device that it was placed on the market after 13 August 2005, doing so in order to determine unequivocally that the waste generated will not be considered historical. This marking is to be made in accordance with the UNE-EN 50419 standard or any standard that replaces the aforementioned one, and it is to be included visibly, permanently, and legibly on each device.
 
 
  • The producer must include their Identification Number provided by the Integrated Industrial Register for Electrical and Electronic Equipment Producers (RII-AEE) in commercial transactions (invoices or documents relating to the transaction or website for online commerce) so that the buyer has a guarantee of compliance with the obligations under this royal decree.
       Standard phrase to include on invoices:          “RII-AEE No.: _______”
 
NOTE: THE COST OF MANAGEMENT CANNOT BE REFLECTED IN THE TICKET OR INVOICE.
(According to articles 7 and 9 of Royal Decree 110/2015, on WEEE)
 
  • The EEE Instructions are to state that before WEEE is deposited at the EEE collection facilities, the batteries should be removed and deposited separately for proper management.

How to Comply: Adhesion Procedure

To join SUNREUSE ASSOCIATION Spanish Collective Extended Producer Responsibility System (SCRAP), the following procedure must be followed:
  1. MEMBERSHIP FORM: The company must complete the "Membership Form” provided by SUNREUSE ASSOCIATION.  The company sends the document once it is completed and signed.
  2. CONTRACT: Using the details from the membership form, SUNREUSE ASSOCIATION will prepare and send the contract to be signed by both parties.
  3. REGISTRATION FORMALISATION: SUNREUSE ASSOCIATION is responsible for registration in. The Integrated Industrial Register for Electrical and Electronic Equipment Producers (RII-AEE) from the Ministry of Industry, Trade and Tourism (MINCOTUR) ↓
Obtaining an RII-AEE number from the Ministry


WHEN THERE IS A CHANGE OF SCRAP:

If the company was already registered in another SCRAP and wishes to join SUNREUSE ASSOCIATION, the following steps must first be taken:
  1. The old SCRAP contract cancellation clauses are reviewed by the SUNREUSE ASSOCIATION legal department.
  2. SUNREUSE ASSOCIATION is responsible for preparing the Request to Cancel the old SCRAP.
  3. Registering in our SCRAP SUNREUSE ASSOCIATION using the aforementioned procedure.
  4. Informing the Ministry of the SCRAP change (during the last quarter of the year).
     
If you need more information, do not hesitate to contact us here or 96 336 34 87
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