Karen Thake outlines the forthcoming Waste Electrical and Electronic Equipment Directive, and sets out what law firms need to do to comply

It might sound far from starry-eyed musings on the cutting edge of technology, but the future of your IT equipment will one day be the mundane environment of the dump. Or at least it used to be. From the beginning of next year, all that will change.


The Waste Electrical and Electronic Equipment Directive (WEEE) is European environmental legislation that aims to minimise the impact of electrical and electronic goods on the environment. The UK government expects to make it law by 1 January 2007, with the main requirements and obligations on producers of equipment coming into force from 1 April 2007.


Typical waste in your office

l IT and telecommunications equipment, such as PCs.

l Lighting equipment, such as lamps, tubes and fixtures (filament light bulbs are not covered by WEEE).

l Smoke detectors and thermostats.

l Televisions, projectors, audio/hi-fi equipment.


WEEE is a high-priority issue because of its growing volume in relation to other forms of municipal solid waste. It has been estimated that the UK generates a million tonnes of WEEE per year.


Without proper waste management, environmental impacts will be huge and very costly. If you are a business user responsible for equipment, you are required to report evidence of its collection, treatment and recovery according to the recovery and recycling or reuse targets.


What you need to do

Gazette readers will most likely be business-end users of WEEE, and as such they must arrange and finance the treatment and environmentally sound disposal of WEEE they discard as waste when they are:


l Disposing of equipment purchased before 13 August 2005 and are not purchasing 'like for like' replacements; or

l Disposing of equipment purchased after 13 August 2005, where the 'responsible producer compliance scheme' cannot be identified.

The user must ensure that the WEEE is separately collected, and obtain and retain proof that it was handed to a waste management company that ensured it was treated and disposed of in an environmentally sound manner.


Keep a paper trail

Mandatory requirements under the duty of care require your business to ensure waste is handled, recovered, or disposed of responsibly; waste is dealt with by a company that is authorised to do so; and a record is kept of all wastes received and transferred by a system of signed notes.


These signed 'Waste Transfer Notes' should be kept for two years. If classified as 'hazardous waste' or 'special waste', consignment notes must be retained for at least three years.


Watch out for CRTs

Cathode ray tubes (CRTs), the computer monitors that look like televisions, are made with lead glass and are classed as hazardous waste, as are televisions themselves. They are increasingly being replaced with liquid-crystal displays (LCDs), which are less bulky and use less energy, but LCDs are also the fastest-growing waste stream in the EU.


CRT monitors constitute WEEE, and the consultation says that business-end users are not required to register under the hazardous waste regulations to dispose of them, so long as the weight of those units being disposed of does not exceed 200kg.


But if your site produces more than 200kg of hazardous waste per year, the law requires you to register with the Environment Agency. If you anticipate that you will produce less but later it appears that you will exceed this limit, you must notify the Environmental Agency before you exceed 200kg. It is advisable, therefore, to register with the Environment Agency now. Reputable waste management companies will help you design a waste scheme.


Providing that your firm is compliant with current law and is open to advice to further improve recycling rates, you will be moving in the right direction towards a more environmentally focused premises that will, in time, reward you, your staff and the environment.


Karen Thake works for London Recycling