Please click on a
link below to view each categorys list of frequently asked questions:
Section A Background Information
2.
Compliance Schemes / Self Compliant
3.
PRL Blackbox
Section B PRL Obligations
3.
VEMCs
4.
Compliance Checklist for New PRL Producer
5.
Submitting EEE Data on the PRL Blackbox
7.
Useful Links
Section C Waste
3. Charging
for Recycling Costs
4. Compliance
Checklist for New
5. Submitting
6. Useful
Links
Section A - Common Requirements
1.1 What is Producer Register?
Producer Register was set
up to assist producer companies in meeting their obligations for the
responsible management of PRL and from September 2008 to meet their
obligations for batteries and accumulators.
The
principal functions of the Producer Register
include:
Registration of producers, importers and
distributors of EEE and/or batteries.
Environmental Protection Agency (EPA)
notification where there is evidence of non-compliance with PRL Regulations.
Verification of visible Environmental
Management Costs (vEMCs) for PRL
Determination of the market share of
individual producers.
Reporting annually to the Minister for the
Environment, Heritage and Local Government on all of these activities.
PRL Register Society has appointed
Deloitte to carry out the latter two functions as the PRL Register Society is precluded by law from seeing the
underlying commercial data. This is described as the PRL Blackbox.
2.1 What is a compliance scheme?
A compliance scheme is a non-profit organisation
that manages the collection, treatment and recycling of PRL, batteries and
accumulators from authorised collection points on behalf of their members. A
compliance scheme invoices its members according to
market share of PRL and/or waste batteries collected. A producer may choose to
become a member of a compliance scheme or they can opt to self-comply.
2.2 What
compliance schemes are there in
At present, there are two
authorised compliance schemes in
(i)
European
Recycling Platform (ERP)
(ii)
PRL
(i) European Recycling
Platform (ERP)
The European Recycling Platform (ERP) is a
pan-European PRL take back scheme which was created in 2002 to comply with the
legal obligations imposed by the PRL Directive. ERPs mission is: to
ensure cost-effective implementation of the PRL Directive, for the benefit of
member companies, their customers, the consumers and ultimately for the
environment and society.
ERP
Tel: +353-1-299-5642
Fax: +353 -1-299-5644
Email: info@erp-recycling.org
Web : www.erp-recycling.org/contact_ireland_eng0.0.html
(ii) PRL
PRL
Tel: +353-1-2999-320
Email: info@producerregister.ie
2.3 Who has to join a Compliance Scheme?
Companies, considered to be
a producer of EEE and/or batteries, have the option of delegating their
responsibilities to one of the two approved compliance schemes or can opt to be
self-compliant.
2.4 How do I
join a Compliance Scheme?
To apply to join ERP Ireland fill in the application form
on ERP Ireland website (www.erp-recycling.org/315.0.html)
or email ERP Ireland at info@erp-recycling.org
or contact ERP on Tel: +353-1-299-5642
To apply to join WEEE
2.5 How will I be charged by my compliance scheme?
The actual costs for each sector's recovery and special
services will be recorded. Fees from a specific sector/category shall be used
exclusively to cover the costs of that sector. No sector shall subsidise any
other sector, neither short-term nor long-term.
The compliance scheme will charge the producer differently depending on the EEE
product and /or battery category.
For EEE producers only:
If you are a producer of products in categories 1, 4, and 5, a visible
Environmental Management Cost (vEMC/PRF) is applied.
The producer must declare (via the PRL Blackbox) how many of these units have
been sold on a monthly basis and the scheme will invoice the producer for the
sum of vEMCs associated with those products.
If you
are a producer of products in a category where no vEMC
is applied.
The compliance
schemes will charge the producer a visible Environmental
Management Cost (vEMC) based the market share.
If you are a Business to Business (B2B) producer, you do
not need to join a compliance scheme, but must become self-compliant. However, you must submit a Waste Management
Plan and Waste Management Report as appropriate to the EPA (Environmental
Protection Agency).
2.6 What do I need to be self-compliant?
Once you have established that you are a producer, the
following needs to be achieved for self-compliance:
Registration with the PRL Register
Society Ltd to obtain a unique registration number. This number should be shown
on all invoice, credit note, dispatch and delivery dockets issued from 13th
August 2005. Provide the PRL Blackbox with the requested data input. A
producer will need to apply for renewal of registration annually as in Articles
10 and 11.
Producer responsibility:
All producers are required to comply with
to the requirements of Articles 16, 17, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28,
40 and 41 of the Waste Management (Waste Electrical and Electronic Equipment)
Regulations 2005 (S.I. No. 340 of 2005) as amended by the Waste Management
(Waste Electrical and Electronic Equipment) (Amendment) Regulations 2008 (S.I.
No. 375 of 2008).
Register with the PRL Register Society in
Finance the take back of PRL from private
households and other users (Article 16 and 17).
Be responsible for the collection of PRL
(Article 19).
Ensure that any collection point and
recovery facility carrying out the treatment of PRL complies with the
technical requirements as set out in the Sixth Schedule (Article 20).
Adhere to the obligations for the
treatment requirements of PRL (Article 21).
Achieve specified recovery rates depending
upon the category and type of the PRL arising (Article 22) and to maintain
documentary evidence of progress on these targets. Producers can obtain this
documentary evidence from their waste management contractors.
Maintain and keep records of all treatment
and recovery data, including specific weights in and out of treatment
facilities, for a period of at least 6 years (Article 23).
Prepare a PRL waste management plan and
provide it to the EPA, at least once every three years (Article 24).
Producers are obliged to
Producers are also obligated to mark their
product with the appropriate marking identifying that the producer of the EEE
has registered with the Registration Body in accordance with their terms and
conditions (Article 27 & Ninth Schedule).
Producers must not use design features or
production processes that make it difficult to reuse or treat the PRL unless
such designs have overriding environmental and/or health and safety advantages
(Article 40).
Obligations under Article 41 on the Reuse
of EEE
3.
PRL Blackbox
3.1 What
is the PRL Blackbox?
PRL Register Society Ltd has
appointed Deloitte to carry out the Blackbox function, i.e. manage the
sensitive market data and
3.2 What is the role of the PRL
Blackbox?
The PRL Blackbox is responsible
for the following functions:
Receipt and processing of data on market
share from registered producers;
Determination of market share based on
product type, producer and/or other criteria e.g., consortia or collective
compliance scheme;
For PRL: advising PRL Register Society
Ltd on the validation of visible environmental management costs where
applicable (costs of collection, treatment, recycling and disposal of PRL);
Advising PRL Register Society Ltd on the
adequacy of financial guarantees;
Providing management reports for PRL
Register Society Ltd; and
Providing year-end reporting by preparing
and sending out annual summaries for each producer and/or compliance
scheme.
Producers should note that the PRL Blackbox is statute-barred from
Section B PRL Obligations
1.1 What is the PRL Directive?
Waste
Electrical and Electronic Equipment (PRL) incorporates any household item that
requires a plug to function and is at the end of its life cycle. In an effort to curtail
environmental problems, the European Commission put forward proposals to
address the growing issue of PRL in
The major provisions of the PRL Directive
are as follows:
All producers and importers of electrical
and electronic equipment (EEE) are required to fund the collection, treatment
and environmentally sound management of PRL from private households and
businesses.
From August 13 2005 onwards, members of
the general public are entitled to have PRL taken back by retailers free of
charge on a one-for-one basis.
1.2 What are the objectives of
the PRL Directive?
The
general objectives of the PRL Directive are:
To prevent the waste of EEE and to promote
the reuse, recycling and recovery of such waste with the overall aim of
reducing overall waste disposal.
To improve the environmental performance
of all operators involved in the life cycle of EEE, e.g. producers,
distributors, consumers and in particular those operators directly involved in
the treatment of PRL.
1.3 Do the
products I make, import or distribute fall under the scope of the PRL
Directive?
The
PRL Directive applies across ten categories of EEE. The following 10 categories have been identified in
the PRL Directive as belonging to EEE:
1. Large
household appliances
2. Small
household appliances
3. IT and
telecommunications equipment
4. Consumer
equipment
5. Lighting
equipment
6. Electrical
and electronic tools
7. Toys,
leisure and sports equipment
8. Medical
devices
9. Monitoring
and control instruments
10. Automatic
dispensers
For a comprehensive product category breakdown please refer to the PRL Register Society
Category Listings which provides a complete breakdown of all EEE
into various categories, subcategories and products to be taken into account
for the purpose of the Directive. All PRL Register Society Category Listings
can be found on the PRL Register Societys website: www.PRLregister.ie
The Category Listing has been compiled for guidance
purposes and is not an exhaustive list.
Producers should contact the PRL Register Society on: (01)
2409320/2409341if they have any specific Category queries.
1.4 Are any
products exempt from the PRL Directive?
The following EEE products are exempt from the PRL
Directive:
Lighting
Equipment; household luminaries, filament light bulbs, including
halogens.
Electrical
and Electronic Tools; large-scale stationary industrial tools.
Medical
Devices; implanted or infected products.
Other exemptions:
Equipment solely for Military and National
Security purposes where the product is specific to that market.
Equipment covered by other existing waste
directives such as the End of Life Vehicle (ELV), e.g. Automotive Products.
-
Equipment which is part of another
equipment type / finished product
Guidance as to whether a product may be in or out of scope
of the PRL Directive on account of it being part of
- a
large scale industrial tool mat be downloaded from the DEHLG website at www.environ.ie/en/Environment/Waste/PRL/PublicationsDocuments/FileDownLoad,14922,en.doc
- another
equipment type / finished product downloaded from the DEHLG website at www.environ.ie/en/Environment/Waste/PRL/PublicationsDocuments/FileDownLoad,14923,en.doc
If you are unsure whether a product falls under the scope
of the PRL Directive please contact the PRL
Register Society on: (01) 2409320/2409341.
2. Producer Requirements
2.1 Do I need
to register In
According to the Waste Management (Waste Electrical and Electronic
Equipment) regulations 2005 (S.I. No. 340 of 2005) as amended by the Waste
Management (Waste Electrical and Electronic Equipment) (Amendment) Regulations
2008 (S.I. No. 375 of 2008) you need to register if you are considered a
producer of EEE:
Producer means any producer who, irrespective of the selling technique used
(including by means of distance communication):
manufactures and sells EEE under his or
her own brand,
resells EEE produced by other suppliers
under his or her own brand,
imports EEE on a professional basis into
exports EEE on a professional basis from
distributes EEE from a producer who is
deemed not to be registered under the provisions of article 12(2) Waste
Management (Waste Electrical and Electronic Equipment) Regulations 2005, with
the exception of a person or persons exclusively engaged in the provision of
financing under or pursuant to any finance agreement unless also acting as a
producer within the meaning of sub-paragraphs (i) to
(v);
2.2 Am I
considered a distance seller?
Distance communication is defined in Article 2(4) of
Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997
as any means which, without the simultaneous physical presence of the supplier
and the consumer, may be used for the conclusion of a contract between those
parties, i.e. products sold over the internet, telesales, mail order etc.
A distance producer incorporates any producer who:
(i) manufactures and sells EEE
under his or her own brand,
(ii) resells EEE produced by other suppliers under his or her own brand,
(iii) imports EEE on a professional basis into Ireland,
(iv) exports EEE on a professional basis from Ireland to another Member State
of the European Union,
(v) distributes EEE from a producer who is deemed not to be registered under
the provisions of article 12(2).
2.3 What are
my responsibilities as a Distance Seller?
Each producer
or distributor in the State who supplies EEE by means of distance communication
(i.e. over the internet, telesales, mail order etc.) must do the following:
Register with the Registration Body, as
per the requirements of Article 10.
Notify the Registration Body that he/she
supplies EEE via distance communication.
Provide
Notify customers that household EEE will
be taken-back at least free of charge on a one-for-one basis.
Take back PRL on a one-for-one basis when
the replacement EEE is being delivered provided that the old appliance is:
i.
Disconnected from public utilities or a
permanent structure.
ii.
Presented for immediate collection and at
least 24 hours notice of delivery has been given.
- If 24 hours notice of delivery has not been given, each
seller must take back PRL within 15
days of the delivery date, provided that the old appliance is:
(i) Disconnected from public
utilities or a permanent structure.
(ii) Presented for immediate
collection and at least 24 hours notice of collection has been given.
- any or every place of business in the State from which a
distance seller distributes EEE and/or an address in the State, while it is occupied
by an employee or agent of the direct seller, within a maximum of 30 days of
the date of delivery of the replacement EEE.
Display
visible Environmental Management Costs (vEMCs),
(SEE WHAT ARE vEMCs? SECTION BELOW):
(i)
On his/her website or other electronic
means of communication, or, as appropriate,
(ii)
In each of his/her catalogues, brochures,
direct mail communications, or, as appropriate.
The price of EEE quoted, displayed and advertised to
members of the public must be inclusive of the vEMC
(i.e. the price of EEE including VAT plus the vEMC =
display price or retail price).
When displaying a vEMC each:
(i) invoice,
receipt or docket issued at the point of sale to the customer,
(ii) website or other electronic means of communication, or, as appropriate,
(iii) catalogue, brochure, direct mail communication or as appropriate,
should state Producer Recycling Fund [amount of environmental management
cost]
Each
producer or distributor outside the State who supplies EEE to householders
in the State by means of distance communication (i.e. over the internet,
telesales, mail order etc.) must do the following:
Register with the Registration Body, as
per the requirements of Article 10.
Notify the Registration Body that he/she
supplies EEE via distance communication.
Notify customers that household EEE will
be taken-back at least free of charge on a one-for-one basis.
Take back PRL on a one-for-one basis when
the replacement EEE is being delivered provided that the old appliance is:
iii.
Disconnected from public utilities or a
permanent structure.
iv.
Presented for immediate collection and at
least 24 hours notice of delivery has been given.
- If 24 hours notice of delivery has not been given, each
seller must take back PRL within 15
days of the delivery date, provided that the old appliance is:
(i) Disconnected from public
utilities or a permanent structure.
(ii) Presented for immediate
collection and at least 24 hours notice of collection has been given.
- any or every place of business in the State from which a
distance seller distributes EEE and/or an address in the State, while it is
occupied by an employee or agent of the direct seller, within a maximum of 30
days of the date of delivery of the replacement EEE.
Display
Environmental Management Costs (EMCs), (SEE WHAT
ARE vEMCs? SECTION BELOW):
(i)
On his/her website or other electronic
means of communication, or, as appropriate,
(ii)
In each of his/her catalogues, brochures,
direct mail communications, or, as appropriate.
The price of EEE quoted, displayed and advertised to
members of the public must be inclusive of the EMC (i.e. the price of EEE
including VAT plus the EMC = display price or retail price).
When displaying an EMC each:
(i) invoice,
receipt or docket issued at the point of sale to the customer,
(ii) website or other electronic means of communication, or, as appropriate,
(iii) catalogue, brochure, direct mail communication or as appropriate,
should state Producer Recycling Fund [amount of environmental management
cost]
Up until 13 February 2006, it was not necessary to display vEMCs in product catalogues. However, the vEMC (visible Environmental Management Cost) and the retail
price must now be shown in a separate brochure, or within three metres of each
entrance to his/her premises and at any location where catalogues are available
and that such a brochure is inserted into any catalogue issued to a consumer.
2.4 Do I have to register in every EU country?
Registration takes place at
individual
No single organisation can
provide effective European-wide compliance. Therefore, it may be necessary to
register in every country where a company has producer responsibilities. For
further
2.5 When am I
fully PRL compliant?
The following steps must be
completed in order to achieve full WEE compliance and in turn receive
certification from the PRL Register Society:
Registration
with the PRL Register Society to obtain a unique registration number.
This number should be shown on all invoices, credit notes, dispatches and
delivery dockets issued from the 13th of August 2005.
Provide the PRL
Blackbox with the requested data input. This includes historical sales data for
the period 01 January 2004 31 December 2005 and monthly sales data for the
period 13 August 2005 Current Reporting Month.
Producers will
need to apply for renewal of registration with the PRL Register Society by the 31st of
January each year as in Articles 10 and
11.
Registration
with an approved compliance scheme (ERP or WEEE Ireland SEE
COMPLIANCE SCHEME SECTION BELOW) or a Self-Compliant Producer - SEE
SELF-COMPLIENCE SECTION BELOW). Producers participating satisfactorily in an
approved compliance scheme are exempt from the provisions of some of the
articles listed below.
Producer
Responsibility:
All producers
are required to comply with the requirements of Articles 16, 17, 19, 20, 21, 22,
23, 24, 25, 26, 27, 28, 40 and 41 of the Waste Management (Waste Electrical and
Electronic Equipment) Regulations 2005 (S.I. No. 340 of 2005) as
amended by the Waste Management (Waste Electrical and Electronic Equipment)
(Amendment) Regulations 2008 (S.I. No. 375 of 2008).
Register with
the Producer Register Limited, pay the appropriate registration fee (Article
10), and provide
Finance the take
back of PRL from private households and other users (Article 16 and 17).
Be responsible
for the collection of PRL (Article 19).
Ensure that any
collection point and recovery facility carrying out the treatment of PRL
complies with the technical requirements as set out in the Sixth Schedule
(Article 20).
Adhere to the
obligations for the treatment requirements of PRL (Article 21).
Achieve
specified recovery rates depending upon the category and type of the PRL
arising (Article 22) and to maintain documentary evidence of progress on these
targets. Producers can obtain this documentary evidence from their waste
management contractors.
Maintain and
keep records of all treatment and recovery data, including specific weights in
and out of treatment facilities, for a period of at least 6 years (Article 23).
Prepare a PRL
waste management plan and provide it to the Environmental Protection Agency
(EPA), at least once every three years (Article 24).
Producers are
obliged to
Producers are
also obligated to mark their product with the appropriate marking identifying
that the producer of the EEE has registered with the Registration Body in
accordance with their terms and conditions (Article 27 & Ninth Schedule).
Producers must
not use design features or production processes that make it difficult to reuse
or treat the PRL unless such designs have overriding environmental and/or
health and safety advantages (Article 40).
Obligations
under Article 41 on the Reuse of EEE.
2.6 Is there
a penalty for non-compliance?
Under Article 15, The PRL Directive states that
Member States shall determine penalties applicable to breaches of the national
provisions adopted pursuant to the Directive.
A producer shall be prohibited from placing/displaying
EEE on the market under the following conditions:
Non-compliance
with any of the provisions of sub-article (1),
If the producer
is deemed not to be registered in accordance with article 12(2),
or, as appropriate.
If the producer is refused an
application for renewal of registration in accordance with the provisions of
article 12(4).
Failure to comply with PRL
Regulations will result in prosecution and you run the risk of severe penalties
with a maximum fine of 15m and/or 10 years imprisonment.
2.7 What EEE
sales data needs to be submitted to the PRL Blackbox?
Please see section 5. Submitting EEE Sales Data To The PRL Blackbox.
2.8 What are the requirements for
distributors (retailers)?
A
Distributor is any person who provides electrical or electronic equipment on
a commercial basis to the party who is going to use it. Retailers fall under
this definition. From 13 August 2005, each retailer must:
register each premises with their local
authority; or
o
register each premises in the in the functional areas of
Limerick
City Council together with Cavan, Clare, Fingal,
Kerry,
all local
authorities other than Limerick City Council together with
Cavan, Clare, Fingal,
Kerry, Limerick, Louth, Meath
and Monaghan County Councils with Producer Register Limited.
provide for free in-store take back of
household PRL on a one-for-one basis on the sale of a new like product;
ensure that any PRL collected is
delivered to an approved collection facility;
ensure that the storage and transport of
PRL collected as above meets the requirements of the Regulations; and
ensure that
private households are
For more
2.9 What about wholesalers are they
covered?
If a
wholesaler is not an importer (i.e. if he/she buys only from local producers
who are registered) and if he/she only sells to distributors (retailers), then
the wholesalers have no obligation under PRL Regulations other than to pass -
- on the vEMC
where applicable in respect of B2C EEE, and/or
- details
of the producer to B2B customers.
2.10 Where do retailers bring the PRL
they collect?
Distributors
who register with their Local Authority are able to dispose of their B2C PRL
at their local Civic Amenity site, provided the site is capable of accepting
PRL. You may also if in the in the functional areas of
Limerick
City Council together with Cavan, Clare, Fingal,
Kerry, Limerick, Louth, Meath and Monaghan County Councils contact ERP, and/or
all local authorities
other than Limerick City Council together with Cavan, Clare, Fingal, Kerry,
Limerick, Louth, Meath and
Monaghan County Councils contact PRL
to arrange the collection of large loads of
B2C PRL from individual retail stores.
3.1 What are vEMCs?
visible Environmental Management Costs
are the costs managing PRL from private households in an environmentally sound
manner that arises from EEE placed on the market prior to the 13th of
August 2005. vEMCs are not taxes or levies. They are not
remitted to Government. They cannot be added onto the price quoted to a
consumer. The PRL Register Society determines the vEMCs
per PRL subcategory. This is done in consultation with the electronic and
electrical industry.
The vEMCs displayed to consumers cannot exceed the
actual costs of recycling household PRL arising from EEE placed on the market
prior to 13th August 2005. They cannot be diverted elsewhere. vEMCs are calculated on the basis
of the estimated number of electrical and electronic appliances that will be
recovered and are subject to change as new
To clarify Producer Recycling Fund- PRF - has the same meaning as visible
environmental management costs vEMC.
All vEMCs are inclusive of 21.5% VAT.
3.2 Who has
to display the vEMC?
From
the 13th of August 2005 onwards, each producer, retailer and distance seller,
must show separately to consumers of EEE the visible environmental management
costs.
3.3
Who do
I contact to inquire about vEMCs?
Producers should contact a compliance scheme (ERP Ireland
or
|
ERP Mr. Martin Tobin 9D, Rathfarnham, |
PRL Mr. Leo Donovan Beacon Court, Sandyford, |
3.4 What are the requirements of PRL Product marking?
Finished EEE products put on the market after 13th August
2005 for the first time in any
Crossed-out
wheeled bin
Unique producer
identification (brand name, trade mark, company registration number or any
other suitable means of identification etc)
Instructions
for recycling and disassembly (if necessary).
The standard applies to both household and non-household
PRL.
Crossed-out wheeled bin: Article 10.3 of the PRL Directive requires Member
States to ensure that producers appropriately mark electrical and electronic
equipment put on the market after 13 August 2005 with the symbol shown in Annex
IV (the crossed-out wheeled bin). In exceptional cases, where this is
necessary because of the size or the function of the product, the symbol shall
be printed on the packaging, on the instructions for use and on the warranty of
the electrical and electronic equipment.
Annex IV: The symbol indicating separate collection for electrical and
electronic equipment consists of the crossed-out wheeled bin, as shown below.
This symbol must be printed visibly, legibly and indelibly.
For the marking of ELECTRICAL AND ELECTRONIC EQUIPMENT in
accordance with the article 10(3) of Directive 2002/96/EC (PRL); you can buy
the standard -ISEN50419- from the
NSAI Standards Sales Office
Tel: 01 8073868
Glasnevin,
Open from 10am to 1pm and 2pm to 4pm. or call Tel: 01
8576730
to buy on line go to www.standards.ie
- Hardcopy 22 (from stock for sameday
despatch)
- Electronic (PDF) 22
Producer identification (brand name, trade mark, company registration number
or any other suitable means of identification etc)
Article 11.2 of the PRL Directive requires that Member States shall ensure
that any producer of EEE put on the market after 13 August 2005 is clearly
identifiable by a mark on the appliance. Furthermore, in order to enable the
date upon which the appliance was put on the market to be determined
unequivocally, a mark on the appliance shall specify that the latter was put on
the market after 13 August 2005. The Commission shall promote the preparation
of European Standards for this purpose.
The standard says that to identify the producer and the equipment put on the
market after 13 August 2005, the following shall be applied to the product:
a unique identification of the producer (a
brand name, trademark, company registration number or any other suitable means
of identification)
the date
of manufacture or date put on the market, either in uncoded
text or in coded text for which the code is made available to treatment
facilities, and/or an additional mark used in conjunction with the crossed-out
wheeled bin symbol. This additional mark is a solid bar, containing no text or
other
If size or other characteristics such as functionality of
the product means that the marking cannot be applied on the product it shall
appear on a flag on the fixed supply cord or in the operating instructions and
warranty certificates included with the product.
4. Compliance Checklist for New PRL Producers
This
checklist is emailed to all newly registered producers. If you have mislaid
your copy, please consult the Producer Register's website by clicking on
the following link: www.producerregister.ie.
5. Submitting EEE Data on the
PRL BLACK BOX
5.1 What
EEE sales data need to be submitted to the PRL Blackbox?
Historical Data
EEE sales data for the period 01
January 2004 31st January 2004 must be submitted at your earliest
convenience vis--vis the excel spreadsheet emailed to you. Please email the spreadsheet
to weeeblackbox@deloitte.ie or
post it directly to PRL Blackbox,
Monthly Data
From the
13th of August 2005 onwards, all EEE distributors must make PRL
submissions to the PRL Blackbox. Submissions are made to the PRL Blackbox on a
monthly basis. All EEE sales data must be submitted to the PRL Blackbox by 12 midnight on the 19th day of each
calendar month for the previous months data.
An exact weight in
kilograms (KG), rather than an estimate, is required when entering
monthly data. All registered users should have received a username and
password via email in order to log on to the website. If you have not received your
log-on details, please contact the PRL Blackbox Helpdesk on +353-1-417-2228.
5.2 Should
my company be making B2B (Business to Business) or B2C (Business to Consumer) B2C submissions?
If an EEE product placed on the Irish
market to be sold to or used by a household consumer, this transaction is
considered B2C, regardless of the supply chain (e.g. from producer to a
wholesaler/retailer etc). If an EEE product is sold to a business, for
professional use only, and that business is the end user, then the product is
considered a B2B transaction.
5.3 Do
weights and units have to be entered?
Exact weights and units must be
entered on the PRL Blackbox as the PRL Directive is weight based.
5.4 How is weight measured on the PRL Blackbox?
Weight is measured in kilograms (kgs) on the PRL Blackbox.
5.5 How do I enter
Please see the PRL Blackbox Website User guide by clicking
on the following link: (link to go in)
6. 1 What is a producer?
I.
A producer
means any person who, irrespective of the selling technique used, including by
means of distance communication
(i) manufactures and sells electrical and electronic
equipment under his or her own brand,
(ii) resells electrical and electronic equipment produced by other suppliers
under his or her own brand,
(iii) imports electrical and electronic equipment on a professional basis into
the State,
(iv) exports electrical and electronic equipment on a professional basis from
the State to another Member State of the European Union, or
(v) distributes electrical and electronic equipment from a producer who is
deemed not to be registered under the provisions of article 12(2).
6.2 What does distributed mean?
I.
distributed means
(i) sold in exchange for any consideration including
money whether or not by finance agreement, including but not exclusive to any
loan, lease, hiring or deferred sale agreement or arrangement relating to any
electrical and electronic equipment whether or not the terms of that agreement
or arrangement or any collateral agreement or arrangement provide that a
transfer of ownership of that equipment will or may take place, or
(ii) giving as a prize or otherwise making a gift.
6.3 What is a distributor?
A distributor
is any person who provides electrical and electronic equipment on a commercial
basis to the party who is going to use it.
6.4 What is distance communication?
distance
communication is as defined in Article 2(4) of Directive 97/7/EC of
the European Parliament and of the Council of 20 May 1997 on the protection of
consumers in respect of distance contracts5 or, as appropriate, means sales and
marketing services by electronic communication, voice telephony services,
including telesales and telemarketing or non-electronic direct marketing
services, including mail order.
6.5 What is electrical and electronic
equipment (EEE)?
electrical and
electronic equipment (EEE) means equipment which is dependent on
electric currents or electromagnetic fields in order to work properly and
equipment for the generation, transfer and measurement of such currents and
fields falling under the categories set out in Annex IA of European Parliament
and Council Directive 2002/96/EC on waste electrical and electronic equipment
and designed for use with a voltage rating not exceeding 1,000 volt for
alternating current and 1,500 volt for direct current.
6.6 What is
waste electrical and electronic equipment (PRL)?
waste electrical
and electronic equipment (PRL)? means electrical and electronic
equipment, which is waste within the meaning of article 1(a) of Council
Directive 75/442/EEC of 15 July 1975 on waste, including all components,
subassemblies and consumables which are part of the product at the time of
discarding.
6.7 What is waste electrical and electronic
equipment from private households?
waste electrical and electronic equipment from private
households means waste electrical and electronic equipment which
comes from private households, and from commercial, industrial, institutional
and other sources which, because of its nature and quantity, is similar to that
from private households.
6.8 What are
environmental management costs (EMCs)?
environmental management costs (EMCs) are the costs
of the environmentally sound management of waste electrical and electronic
equipment from private households arising from electrical and electronic
equipment placed on the market prior to 13 August 2005.
6.9 What is the environmentally sound
management of waste electrical and electronic equipment?
The environmentally
sound management of waste electrical and electronic equipment is the
collection, storage, treatment and recovery or, as appropriate, disposal of
waste electrical and electronic equipment in an environmentally sound manner.
6.10 What is the producer recycling
fund?
The producer
recycling fund has the same meaning as environmental management costs.
6.11 Who is the final user?
The final user
is any person who discards electrical and electronic equipment, for which they
have no further use or, as appropriate, who intends to or is required to
discard it, but shall not include any person who on behalf of or as a service
to any other person
(i) buys, sells or arranges for the purchase, sale or
transfer of waste from one person to another, or
(ii) arranges for the collection, recovery or disposal of waste.
6.12. What is a civic amenity
facility?
A civic amenity facility is a purpose-designed
facility operated by or on behalf of a local authority or a private sector
operator which is provided for the efficient reception and temporary storage of
recyclable and non-recyclable waste materials, including segregated waste
electrical and electronic equipment arising from private households.
6.13 What is a
collection point?
A collection point
is:
(i) a civic amenity facility, or
(ii) other facility for the receipt, storage or recovery of waste electrical and
electronic equipment subject to such a facility being appropriately licensed,
permitted or registered under Regulations made pursuant to Section 39 of the
Act, or other such facilities as may be prescribed in Regulations.
6.14 What is the interpretation of
placed on the market?
Placed on the market means the supplying
or making available to an end user within an EU Member State for the first
time, against payment or free of charge, EEE and/or batteries.
6.15 Do I need to include the weight of
a battery when making EEE submissions?
From 26th September 2008, all
producers making EEE submissions to the PRL Blackbox should exclude the weight
of all batteries and accumulators from the weight of the EEE as battery weight
should be submitted to the PRL Blackbox separately.
1.
Useful Links
Links to be provided to the following:
- Producer Register
- PRL Blackbox
- PRL Category Listings
http://www.PRLregister.ie/categories.html
- ERP
- PRL
- PRL Regulations
http://www.environ.ie/en/Environment/Waste/PRL/RHLegislation/FileDownLoad,1360,en.pdf
http://www.environ.ie/en/Legislation/Environment/Waste/PRL/FileDownLoad,18495,en.pdf
Section C Waste
1.
1.1
What is
the scope of the Batteries Directive 2006/66/EC?
The Directive applies to all batteries
and accumulators placed on the Community market. In line with Article 2(3) of
the PRL Directive, batteries and
accumulators used in equipment connected with the protection of the essential
security interests of the Member States are excluded from the scope of this
Directive. Equipment designed to be sent into space is also excluded from the
scope of the Directive.
1.2 Why
does Directive 2006/66/EC apply to all batteries and
not just to hazardous ones?
Directive 2006/66/EC applies to all
batteries because:
all batteries contain
substances which are more or less harmful to the environment;
experience with
the previous Directive (91/157/EEC) on hazardous batteries (batteries
containing mercury, cadmium or lead) showed that all battery collection schemes are more efficient than
separate schemes for certain types of portable batteries;
all batteries contain metals which are
recyclable, so the
collection and recycling of all batteries help save resources in conformity
with Article 174 of the EC Treaty.
1.3 What is the objective of the Batteries
Directive?
The objective of the Directive is twofold:
1. To contribute to a high level of environmental
protection
2. To contribute to the proper functioning of the internal market.
1.4 What is the definition of battery
producer?
According to the
definition in Article 3 of the Directive, the producer is the person in a
1.5 Who is the battery producer?
Examples
- A
battery manufacturer or a domestic importer sells batteries to a retailer who in
turn sells them to end-users in the same
In this case, the battery manufacturer or
the domestic importer is the producer in that
− A retailer sells batteries in a
In this case, as the retailer is placing
these batteries on the market for the first time in the given
− An equipment/car manufacturer buys
batteries within a
A battery manufacturer or domestic
importer in a
− A car/equipment
manufacturer buys batteries outside a
Since in this case it is the
equipment or car manufacturer or domestic importer who places these batteries
on the market of the
− A company imports
batteries from a non-EU parent company for its independent subsidiary located
in a
In this case the
independent European subsidiary is the producer, as it is the subsidiary, which
places the batteries on the market in that
1.6 What are the different types of batteries?
Portable battery or accumulator means any battery,
button cell, battery pack or accumulator that;
(a) is
sealed
(b) can be
hand-carried, or as appropriate
(c) is
neither industrial or automotive
Primary batteries or
accumulators are non-rechargeable
Secondary batteries or accumulators are rechargeable
Automotive battery or accumulator means any battery
or accumulator used for automotive starter, lighting or ignition power.
Industrial battery or accumulator means any battery
or accumulator designed exclusively for industrial or professional use where it
weighs more than 2Kg as an individual cell or pack.
1.7 How
do I know what type of battery I import?
The Batteries Directive 2006/66/EC also provides everyday
examples of industrial & portable batteries in the recitals:
Examples
of industrial batteries and accumulators include:
- batteries and accumulators used for
emergency or back-up power supply in hospitals, airports or offices,
- batteries
and accumulators used in trains or aircraft and batteries and accumulators
used on offshore oilrigs or in lighthouses.
- batteries and accumulators designed
exclusively for hand-held payment terminals in shops and restaurants,
- bar code readers in shops,
- professional video equipment for TV
channels and professional studios,
- miners' lamps and diving lamps
attached to mining and diving helmets for professionals,
- back up batteries and accumulators
for electric doors to prevent them from blocking or crushing people,
- batteries and accumulators used for
instrumentation or in various types of measurement and instrumentation equipment
- batteries and
accumulators used in connection with solar panel, photovoltaic, and other
renewable energy applications.
- Industrial
batteries and accumulators also include batteries and accumulators used in
electrical vehicles, such as electric cars, wheelchairs, bicycles, airport
vehicles and automatic transport vehicles.
- In
addition to this non-exhaustive list of examples, any battery or
accumulator that is not sealed and not automotive should be considered
industrial.
- batteries
and accumulators which meet the definition of industrial batteries in the
Regulations with a weight greater than 2Kg
- It has
been clarified that for hybrid cars, 12V batteries are used for
automotive starters, whereas lithium ion or Nickel Metal Hydride batteries
are used mainly for propulsion.
Examples of portable
batteries and accumulators, which are:
- all-sealed batteries and accumulators
that an average person could carry by hand without difficulty and that are
neither automotive batteries or accumulators nor industrial batteries or
accumulators and weigh less than or equal to 2Kg, include:
- single cell batteries (such as
AA and AAA batteries)
- batteries and accumulators
used by consumers or professionals in mobile telephones, portable
computers, cordless power tools, toys and household appliances such as
electric toothbrushes, razors and hand-held vacuum cleaners (including similar
equipment used in schools, shops, restaurants, airports, offices or
hospitals) and any battery or accumulator that consumers may use for
normal household applications.
2.1 Who will pay for the collection, treatment
and recycling of batteries?
Article 23 of the Waste Management
(Batteries and Accumulators) Regulations 2008 (S.I. No 268 of 2008) as amended by Waste Management (Batteries and
Accumulators) (Amendment) Regulations 2008 (S.I. No. 556 of 2008) states
that on and from 26th September 2008, each producer shall ensure
that he or she or a third party acting on his or her behalf finances any net
costs arising from waste batteries deposited at a collection point or civic
amenity facility, collected from end-users, waste industrial batteries and any
public
2.2 What are the battery collection
requirements?
The Batteries Regulations aims at as much
collection of spent batteries and accumulators (portable, industrial and
automotive) as possible. To this end it specifies the following collection
requirements:
End users of portable batteries
and automotive batteries from private, or as appropriate, non commercial
vehicles, must be able to bring waste batteries to collection points in
their vicinity, free-of-charge and without obligation to buy a new battery;
Distributors must take back waste portable
batteries when supplying portable batteries (unless it is proven that the existing
alternative schemes are as effective);
Producers of industrial batteries,
or third parties acting on their behalf, are obliged to take industrial
batteries back from end-users;
Producers of automotive
batteries, or third parties, should set up collection schemes for waste
automotive batteries not collected through collection schemes set up under the
Directive on end-of-life vehicles (ELV Directive)..
2.3
Do I need to register In
If you are deemed
to be a producer as per the definition above, then you are obliged to register
as a producer in
2.4
Do I have to register in every EU country?
Each EU Member
State will have established its own regulations. It
is advisable that all producers should contact the Member States registration
body.
2.5
When am I deemed to be registered with the National
Registration Body?
A producer is
registered when they receive their certificate from the registration body, and have
confirmed that they meet all criteria for registration as per the application
form.
2.6
Is there a penalty for non-compliance with the
Article 48 of the Battery and Accumulator
Regulations S.I. No. 268 of 2008 outlines possible prosecutions and penalties,
where convicted on indictment, a fine to a maximum of 500,000, or imprisonment
for a term not exceeding 3 years, or both.
2.7
What
battery sales data needs to be submitted to the PRL Blackbox?
Producers should submit the exact weight
and chemistry of batteries placed onto the market excluding any batteries that
left the state prior to being sold to end-users. Please see Point 5 below for more
2.8
What are
the requirements for distributors (retailers)?
Article 21 outlines Distributor Responsibilities including the free of
charge receipt of waste batteries of an equivalent type placed onto the market
and the provision of conveniently located appropriate facilities for the
collection of waste batteries.
For
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,18490,en.pdf
2.9
Where
do retailers bring waste batteries & PRL they collect?
Presently Retailers should register with their local authority to allow
them to store (subject to certain weight thresholds) and deposit at local civic
amenity sites, or similar.
3.
Charging for
Recycling Costs
3.1 What environmental management costs are
applicable to waste batteries?
Producers should
contact their appropriate compliance scheme (ERP or PRL
4.
New
This
checklist is emailed to all newly registered producers. If you have mislaid
your copy, please consult the Producer Register's website by clicking on
the following link: www.PRLregister.ie.
5.
Submitting
A total weight in kilograms (KG), rather than an estimate, is required when
entering monthly data.
The Batcon application has been developed to facilitate those
producers who are unable to determine either the weight or chemistry of a
battery placed on the Irish market from their own records. The Batcon application converts battery volumes into associated
average weights and chemistries. The link to the Batcon
application can be accessed from the PRL Blackbox, once you have logged on to
it. Users of the Batcon application must export the
converted weights and chemistries to the PRL Blackbox and save their
submissions as complete.
6.
Useful Links
Links to be
provided to the following:
- Producer Register Limited
http://www.producerregister.ie/
- PRL Blackbox
- ERP
- PRL
- Batteries Regulations
http://www.environ.ie/en/Legislation/Environment/Waste/WasteManagement/FileDownLoad,19240,en.pdf