Starting UK Electronics Business – Regulation

Regulations that are specific to electronics are mainly inspired by the EU, but the British interpretation of them has been as bureaucratic as possible. I am not an expert on these regulations, and the only people who are talk with a nasal whine and keep coloured pens neatly in their shirt pocket.

The main ones at present are RoHS (Restriction of Hazardous Substances), WEEE (Waste Electrical and Electronic Equipment) and CE marking but RoHS is being revised as RoHS2 at the moment.

RoHS

These are often called the “lead free directive” and mean that restricted substances cannot be included in any product sold in EU, whether it is made here or not. It is easy to comply with and clearly states what is allowed. As a new producer (or importer) you should use lead free PCBs and solder and make sure all your component or product supplies come with a statement of conformity that they are RoHS free.

WEEE
These regulations were a nightmare to understand, and were introduced before the Environment Agency (EA), who enforce them, had even worked out how they were going to interpret them – officialdom at its worst.

A “producer” can be an importer by the way. What they actually mean is that you must clearly label all your products with your brand and include a wheelie bin symbol on them. Then you register with a WEEE compliance scheme, pay them a fee that includes EA registration, and submit quarterly data on the amount of electronic equipment you placed on UK market in that period, to the nearest Kilo.

In return you get a WEE producer number that must appear on your invoices. There are no exemptions for small size, just a smaller fee, therefore all those people on Ebay who import a few electronic bits should register!

So far, so good but if you sell direct to consumers (B2C) you need to pay an extra fee as your share of costs of local recycling centres but your WEEE compliance scheme can advise you. And don’t forget the Battery Regulations if you supply more than 32Kg of batteries per year in your products or on their own, again ask your compliance scheme.

Finally, there are 10 categories of WEEE, with different rules for each category and you need to decide what category fits your products. I am still unclear about exports to the rest of the EU and have never got a clear answer. There is one school of thought, mostly bureaucrats, that says you should register in every country you supply, up to 27 fees, 27 data submissions and 27 WEEE numbers, but I go with the view that a UK registration number is all you need, and our EU customers seem happy with this.

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