RLG Company logo Home button

EPR Assessment of Electrical and Electronic Equipment for B2C or B2B use

October 20, 2022

The European WEEE Directive 2012/19/EU covers and specifies how to report Electrical and Electronic Equipment (EEE) used by consumers and EEE intended for professional use. “B2C” (business to consumer) and “B2B” (business to business) are the terms primarily used in this context.

When looking at EPR obligations, (amongst others) three criteria are relevant for a preliminary assessment:

1) Does the company match the producer and/or distributor definition?

2) Are the EEE products in the scope of the regulations?

3) Are the EEE products B2C, B2B, or dual-use equipment?

When a company matches the producer and/or distributor definition and has EPR obligations, it is essential to look at criteria 2) and 3). For the scope, Article 2 of the European WEEE Directive specifies seven exclusion categories, for example, equipment sent into space or used for military purposes. Therefore, EEE products that do not match any of these exclusions are in scope. This logic is known as the so-called “open-scope.”

Moving to criterion 3), besides the way EEE products are distributed, attention must be drawn to the intended use. For example, a company sells medical equipment clearly designed for professional application and only intended to be used by hospitals. The medical equipment does not match any of the seven exclusion categories and is in scope. The equipment is only used in a professional context, so it can be considered B2B EEE. Along with the medical equipment, the company delivers a laptop used to navigate the medical appliances and is equipped with analytical software to display results. Even in this case, the laptop is considered dual-use as it could be used as a “normal” laptop. Although the software installed on the laptop may be designed only to analyze medical data, authorities and collective schemes barely ever recognize this as a relevant factor. As laptops could be wiped and reinstalled and are typically used in private surroundings, an interpretation of exclusively professional use is mostly rejected by national authorities. This example shows that the scope and differentiation of B2B and B2C are not always entirely clear.

RLG can help you with scoping questions and ensure that your products are reported correctly.

Latest news

Textile EPR Implementation in the EU

Background:The Sustainable and Circular Textiles Strategy sets out a vision for the textiles industry's transition. By 2030, the EU market will feature durable, recyclable, largely recycled, and eco-friendly textile products. Consumers will enjoy longer-lasting, affordable textiles, moving away from fast fashion, with profitable reuse and repair services readily available. Producers across the value chain will […]

Read More
Driving Change: Exploring the Impact of RLG's Deposit Return System Pilot in Serbia with Business Development Manager Jelena Simic

In October 2022, our project for an innovative deposit return system (DRS) based on marking products with unique coding turned into a live pilot system with 20 collection devices (Handhelds, RVMs, E-bins) in 12 locations across Zrenjanin, Serbia. The pilot is currently in the final stage and has greatly impacted the local area, driving behavioral […]

Read More
Ecomodulation: Shaping the Future of Waste Management

The European Commission adopted the new Circular Economy Action Plan (CEAP), an initiative aimed at making production in the European Union more eco-friendly. To bolster this plan, existing directives on waste and packaging were revised, and new laws were introduced to address the environmental impact of plastic use. A crucial milestone was the approval of […]

Read More
menucross-circle linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram