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EU Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE)
Here is a brief summary of Woodward's position on the EU directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE).
In regards to the applicability of the European WEEE Directive, Woodward worked closely with Krug und Petersen Government Affairs & Consulting GmbH (KuP GA) to obtain a legal assessment on the applicability of the WEEE directive to the various electrical and electronics products supplied by Woodward.
This legal assessment identifies six criteria within the WEEE "Frequently Asked Questions" (FAQ) materials that determine whether products fall under the WEEE Directive as finished products, or do not fall under this legislation because they represent components or parts of a fixed installation. On the basis of the application of the noted criteria, Woodward regards the WEEE directive as not applying to Woodward products as supplied to our customers.
In addition to this legal assessment, Woodward directs customers specifically to the WEEE FAQ materials available from the EU at http://europa.eu.int/comm/environment/waste/pdf/faq_weee.pdf. Of particular interest is Question 1.3: What is the criteria for determining whether a product falls under the WEEE Directive?
- Item Nr 1 of this section notes that to fall under the WEEE directive, the equipment in question would need to be dependent on electricity as its primary energy source to fulfill its basic function, and specifically notes that equipment that uses petrol or gas as its primary energy source does not fall under the directive.
- Item Nr 3 of this section notes that large-scale industrial tools (i.e., machines or systems consisting of a combination of equipment, systems, finished products, and/or components) designed to be used in industry only, do not fall under the WEEE directive.
- And Item Nr 5 of this section states that equipment in a fixed installation (and not intended to be placed on the market as a single functional or commercial unit) also do not fall under the WEEE directive.
Based on the KuP GA legal assessment and supported by the FaQ information cited, Woodward regards the WEEE directive as not applying to Woodward products as supplied to our customers.
Any customer questions regarding this issue should be addressed to the customer's Woodward account manager or representative.
If you have any additional questions regarding this issue, I welcome hearing from you.
Woodward RoHS Statement