Custom WEEE reporting and collection records development
Most businesses subject to the WEEE rules don't realise they are. Since the open scope took effect on 15 August 2018, every product with an electrical function counts, which means a furniture maker with lighting in a cabinet is just as much a producer as a washing machine manufacturer. The question is therefore not how to report, but what.
The scope question comes first
Until 2018 the regulations worked from a list of product types: if your product wasn't on it, you were outside the scope. Since 15 August 2018 the open scope applies and that list is gone. In principle every product with an electrical function now falls under it, even when that component is incidental: a cabinet with LED lighting, a desk with a charging point, packaging with an electronic label, an installer supplying solar panels. Businesses that never thought of themselves as electronics producers have, since then, become them.
The obligations are set out in the Regulation on Waste Electrical and Electronic Equipment, known in practice as the Regeling AEEA; WEEE is the English abbreviation for the same stream. A producer registers with the register, the Stichting Nationaal (W)EEE Register in Zoetermeer. In practice this is often done through membership of Stichting OPEN, the producer organisation that runs collection collectively; it handles your registration, but the obligation itself remains yours.
Pay attention to which date applies to you. Producers must submit their data on the previous calendar year to the register by 1 May each year. That is the AEEA reporting deadline your accountant and regulator will ask about. The 1 July date often mentioned is the register's report to the minister, not your deadline. Both appear in articles 18 and 19 of the Regeling AEEA. Aiming for July means being two months late, and the data still missing at that point is precisely the scope assessments nobody wants to carry out in the spring.
Electronics is one stream; packaging and batteries are others, each with its own registration per member state. An overview is available at software for EPR registration by EU country.
How we build your WEEE administration
Almost all the work happens before the first line of code: establishing which items count. Once that is settled, the reporting itself is a matter of addition.
Not per product group but per item, because within one series one variant may have a light and another may not. This is the step that takes up the most time and where most of the surprises lie.
For each item, the outcome with the reason and the date. An inspector does not ask why something is in your return, but why something is NOT in it, and then what counts is whether you weighed it at the time or are thinking of it on the spot.
Each sprint delivers something you can check yourself. We start with the scope determination and the item data, because without those two, calculating makes no sense.
We have the system calculate a closed year and set the outcome against your previous return. Differences almost always point to items that were quietly left out of scope.
What the administration concretely does
Two components carry this system: the scope assessment per item and the conversion to kilograms per category. The other four depend on these.
Scope assessment per item
A fixed route of questions that results in in scope or not, with the reason, the assessor and the date recorded. New items automatically enter the queue, so the assessment happens at introduction and not in April.
From units to kilograms per category
For each item a weight and a category, with which the system performs the conversion. If a weight is missing, it is shown as an open point rather than quietly estimated.
Keeping the 1 May deadline in view
A countdown to your own submission date, showing which items still lack an assessment or a weight. That way, by February, it is already visible what will block the return.
Volumes from your ERP
Sales, returns and receipts from your existing system, so the return rests on the same figures as your administration rather than on a parallel count.
Collecting weights from suppliers
The weights you are missing are usually held by your producer. A portal in which they supply them per item works better than an email exchange with files in varying formats.
Take-back obligation and return flows
What has been taken back, where it went and which processor handled it. If you sell to consumers, you often have a take-back obligation and this becomes a second administration alongside the return.
Who we build for
Four positions, ordered by how visible the electrical part of your product is. The less visible it is, the greater the chance that you are currently outside the scheme while that is not correct.
Products with a small electrical component
Furniture with lighting, solar panels, heating equipment, packaging with an electronic element. Here the question of whether you fall under the scheme is often not answered at all, and that is the first and most costly step.
Equipment manufacturers
The scope is clear for you; the work lies in the category classification and in weights per item for a range that changes regularly. If production runs through a MES, the weight is usually already known there.
Importers and distributors
You import and are therefore a producer, even without your own factory. Your risk lies with items you resell under a foreign brand, because it is then not self-evident who files the return. If you are on the processing side of this flow, waste collection software concerns routes and containers and metal recycling software concerns material flows and purchase value; this page is written from the producer's side.
Own-brand retail
For bought-in brands you are usually not the producer, but for your own brand you are. On top of that comes the take-back obligation in store, which gives you, on the processing side, an administration you can share with your returns management; that concerns commercial returns, whereas this concerns the waste phase.
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The build comes down to one thing: that a scope assessment is a decision that stands, and not a tick box that someone later quietly changes. That is what determines how we set up the record-keeping.
Why Appfront
The scope covers the entire question
Since the open scope, products fall within it that businesses don't suspect. We build the assessment as a documented decision, because the question afterwards always concerns what you did not declare.
Your deadline is 1 May, not 1 July
This confusion costs businesses two months every year. We enter your own deadline into the system and count down to it.
Assessment at introduction
A new article added to the range immediately enters the review queue via integrations. That's the difference between ongoing maintenance and a catch-up exercise once a year.
Honest about what we don't do
Whether a specific article falls within scope is a legal assessment. We provide the route and the record; the judgement remains yours or your adviser's. And do expect that this assessment will make your range larger than you currently declare, not smaller: under the open scope, that is the usual outcome, and it costs you money.
Security and privacy
This administration contains hardly any personal data, but it does contain sensitive business information: your volumes per category are a direct derivative of your turnover and range. If you operate under private label or for multiple brands, confidentiality towards those parties also comes into play. We therefore keep access tight and separated per entity.
Scope assessments require more careful handling than the figures themselves. They are the evidence that you made a judgement at the moment the article was introduced, and that value disappears as soon as someone can alter an old assessment. A reassessment is therefore stored alongside the original, recording who and when, and does not overwrite it. The same applies to data your supplier delivers: we keep it as it arrived. For how we handle security ourselves, see our information security policy; reports from outside go through our CVD policy.
Frequently asked questions about the WEEE declaration
Since 15 August 2018 the open scope applies: in principle, every product with an electrical function falls within it, rather than a delimited list of product types. As a result, businesses that do not consider themselves electronics producers are also included, such as a furniture maker with lighting in a cabinet. Assessing each article is legal work; we build the system that records the outcome with justification and automatically places new articles in the queue.
Annually before 1 May, covering the previous calendar year, to the register. This is a different date from the 1 July you often encounter: that is the reporting by the Nationaal (W)EEE Register to the minister, not your deadline. It is the most common mistake in this matter and it costs two months.
The scheme states that a producer registers with the register, the Stichting Nationaal (W)EEE Register in Zoetermeer. In practice, most producers join Stichting OPEN, the producer organisation that carries out collection collectively, and registration is thereby arranged. Two things, with one action: joining transfers the collection, while the declaration of your own volumes remains your responsibility.
The whole product, and that is where the pitfall lies. The weights are usually held by your manufacturer or supplier. A workable approach is a portal in which they supply those per item, with a list of what is still missing. What makes this different from other schemes: it concerns the weight of the entire product, not just the electrical component. A cabinet with an LED strip weighs as a cabinet.
The scheme covers what is placed on the market in the Netherlands. What you import and then export does not, in principle, count towards it. Have your lawyer confirm the precise treatment, or check with the register; we make sure the system tracks both flows separately so you can draw the distinction.
Yes, as a second record alongside the return: what was taken back, where it went and which processor handled it, with their certificate attached. If you sell to consumers, you often have a take-back obligation. You will want that flow in the same system as your commercial returns, but recorded separately, because only the waste stage counts under this scheme.
The record-keeping looks similar, but the bottleneck is different. With UPV textiles you usually know what falls under it, and the difficulty is demonstrating percentages over goods you no longer hold. Here it is the reverse: processing is arranged collectively, and the difficulty lies at the front end, in determining which of your items count.
Build a WEEE administration?
Send us your product list and we'll go through it with you for electrical function. Almost every time, product groups turn up that nobody knew counted, and then at least you know where you stand. We build this as a standalone application and as part of a broader custom software project. The PPWR applies to the packaging around your equipment; see PPWR software.