The EA has finally, after two years of discussion, published the updated guidance on when used EEE becomes waste. This is an extremely important piece of guidance as it not only has a big impact on the reuse sector, but also on legitimate WEEE businesses in ensuring that they have something to point to when approached by the grey market, especially dubious exporters.
One of the major concerns about this guidance, however, is that is makes it very difficult to reuse components rescued from used EEE or WEEE as the guidance states:
‘If during repair or refurbishment the holder decides an item of EEE is not suitable for its current use and dismantles it into its different components, then the EEE has been discarded and so becomes WEEE. The dismantled components that are removed from an item of WEEE are waste. To reuse these components, for example to refurbish another item of EEE, the components must meet the end of waste requirements. This includes assessment for, and management of POPs.’
For the default position to effectively rule out reuse does seem to go against government Circular Economy aspirations when the risk related to further use would seem to be extremely low, if not non-existent. Hopefully, the EA will reconsider.