WEEE management for businesses: obligations and traceability

Updated on 7 min read
Conveyor belts with stockpiles of shredded material

A company that produces WEEE (waste electrical and electronic equipment) – computers, air-conditioning equipment, machinery with electronics, the appliances in a staff canteen – is required to hand it over to a waste management company authorised for WEEE and to be able to prove it with documents, starting with the waste tracking sheet for each shipment. WEEE management for businesses comes down to three things: complying with the regulations, keeping every item traceable until it is treated, and recovering the metal it contains.

What WEEE does a business produce?

More than you might think. As well as IT equipment, there is electrical equipment in almost every area:

AreaExamples
OfficeComputers, servers, monitors, printers, phone systems, routers and switches
Production and maintenancePower tools, control and automation equipment, measuring instruments, machinery with electronics
Air conditioning and building servicesAir-conditioning units, heat pumps, boilers, extractor fans
Canteen, kitchen and facilitiesFridges, dishwashers, ovens, vending machines

If you’re not sure whether a particular piece of equipment counts as WEEE, our article on what WEEE is gives the definition and the seven categories.

What are your company’s obligations as a holder of WEEE?

The WEEE regulations, which in Europe stem from Directive 2012/19/EU, and Spain’s Law 7/2022 on waste and contaminated soils translate into five practical obligations:

  1. Hand it over to a waste management company authorised for WEEE, or to the system organised by the equipment’s producer. A scrap dealer without that authorisation can’t accept it.
  2. Don’t mix it with scrap metal or general waste, and keep incompatible categories apart.
  3. Store it safely while it waits to be collected, especially items that contain batteries.
  4. Document every handover with the paperwork we set out below.
  5. Keep that documentation for inspections and audits.

It isn’t only the authorities who ask for this paperwork. So does your ISO 14001 auditor, and so does the purchasing department of a large customer when it vets its suppliers.

What is a producer compliance scheme, and how does it differ from the direct route?

Producer compliance schemes, known in Spain as SCRAPs (sistemas colectivos de responsabilidad ampliada del productor), are not-for-profit organisations that bring together manufacturers and importers of equipment so they can meet their collection and recycling targets. They fund WEEE management and arrange for it to be taken from their distribution centres, retailers and collection points to the treatment plants.

The other route is the direct one: the company that produces the waste, or an approved intermediate waste operator, delivers it to the plant or books a collection. For your company, the practical difference lies in who organises and pays for the collection and on which platforms each delivery is reported. You don’t have to choose blindly: when you book a collection, we tell you which route applies and, if you don’t have a compliance scheme assigned, we assign one.

How does WEEE traceability work?

WEEE traceability goes beyond a delivery note showing tonnes. Each item or batch carries a unique tracking label, digital or printed, that stays with it from the moment it leaves your company, through any intermediate operators, until it reaches the treatment plant. On arrival it is weighed on a trade-approved weighbridge, assigned its WEEE EWC code (European List of Waste) and linked to the treatment case file.

The waste management company then has to report that delivery. In Catalonia, in three places:

PlatformWhat is reported
The Ministry’s WEEE e-platform (MITECO, Spain’s environment ministry)All incoming WEEE, with its WEEE EWC code
SDR, the Catalan Waste Agency’s online documentation systemThe same deliveries in the regional system, which isn’t integrated with the Ministry’s
The compliance scheme’s platformKilograms by category, for invoicing and the producer’s targets, when the delivery comes through that route

We explain why traceability protects whoever produces the waste in the importance of traceability in industrial waste.

What documents should you keep for each handover?

DocumentWho issues itWhat it does for you
Waste tracking sheetIt accompanies every shipment; if your waste reaches Alberich without one, we produce itShows that the waste went from your company to an authorised waste management company
Weighbridge ticketThe waste management company, on a trade-approved weighbridgeGross, tare and net weight of what you delivered
Goods-received noteThe waste management companyDetails of what was received, and the basis for invoicing or valuation
Certificate of treatmentThe waste management company, on requestCertifies final treatment; useful for ISO audits and compliance reports

Keep it all together, in date order. WEEE with hazardous components has codes marked with an asterisk. Law 7/2022 requires anyone who produces hazardous waste, and anyone producing more than 10 tonnes a year of non-hazardous waste, to keep a chronological record and retain it for at least five years. Even if neither applies to you, it’s worth keeping your documentation for the same length of time.

What should you ask of a WEEE management company?

Before you sign an agreement, check these points. They apply to any waste management company:

What to checkWhy it matters
Specific authorisation for WEEE, verifiable in the regional registerHanding waste to someone who isn’t authorised is an offence on the part of the holder
Where each category is depollutedSo you know who removes the gases, oils and batteries, whether at their own plant or through a documented transfer
Protocol for lithium batteriesThey are one of the most frequent causes of fires in warehouses and waste plants
Reporting to the mandatory platformsIf the company doesn’t report, your handover isn’t on record
Logistics suited to your volumeContainers, frequency, and one-off collections when you replace equipment

WEEE management for businesses: how we work at Alberich

We are an authorised final treatment plant for WEEE, with authorisation for every category: some we treat at our own plant, and others, such as cooling appliances (fridges and freezers), we transfer with their documentation to specialist operators. We take in WEEE by both routes: from the leading compliance schemes in the sector and directly from companies and intermediate operators. With a company, the process works like this:

  1. You tell us what type of WEEE you have, the approximate volume and how often you produce it. We reply within 48 working hours.
  2. We agree the route (compliance scheme or direct), the format (container from 1 to 30 m³, pallet or bulk bag) and the frequency: monthly, quarterly or a one-off collection.
  3. We collect with our own fleet, or receive your lorry at the plant, and weigh the load on a trade-approved weighbridge.
  4. We depollute, treat and report each delivery on the relevant platforms.
  5. We give you the documentation for each handover and, if you ask for it, the certificate of treatment.

The value of the metal in your equipment is reflected in our proposal: the more iron, copper and aluminium, the more value is recovered; the more plastic, the less. We explain what is recovered from each type of appliance in our guide to appliance recycling. We hold ISO 9001, 14001 and 45001 certification.

Frequently asked questions

Can I sell my company’s WEEE as scrap metal?

No, unless whoever collects it is a waste management company authorised for WEEE and treats it as such. If it’s sold as mixed scrap, nobody depollutes or reports it, and as the holder of the waste you risk a penalty.

How should I store equipment with lithium batteries until it is collected?

Keep it apart from everything else, under cover, somewhere dry and away from heat sources, and don’t stack it in a way that could crush it. If a battery is swollen or damaged, separate it and tell the waste management company before the collection: it needs specific packaging and transport.

How often should collections be scheduled?

It depends on how much you produce and how much space you have. Companies with a steady flow usually work with monthly or quarterly collections; those that replace equipment all at once, with a one-off collection timed to coincide with the changeover. Storing it up for months doesn’t save money and increases the risk in your storage area.

Is the certificate of treatment mandatory?

No. What is mandatory is for the handover to be documented with the waste tracking sheet and the waste management company’s records. We issue the certificate of treatment on request, for a fee, and it is usually requested by companies that need it for their ISO 14001 certification or to report to their customers.

If your company produces WEEE regularly or has an equipment upgrade coming up, tell us what volume you handle and we’ll propose the route, the format and the frequency.

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