FAQ Environmental

  • Do my products fall into scope of the WEEE Directive (2002/96/EC)?
    According to the WEEE-directive (transposed to Dutch local law to become effective) electric and electronic equipment are devices, which use electricity, either through a cable, battery or powered by another device. Additionally all peripheral equipment does fall within the scope. Peripherals include external modems, external drives, mice, keyboards, VDUs, etc.

    There are exemptions from the WEEE legislation; one of the exemptions is that the legislation only addresses finished goods. Parts do not fall within the scope of the WEEE directive. Examples of parts include: internal modems, motherboards, sound cards, internal drives, coolers, etc.

    If you are not comfortable whether your products are within scope of the WEEE directive feel free to contact Pincvision.

  • What are my obligations under the Battery Directive (2006/66/EC)?
    The Battery Directive applies to all batteries and accumulators introduced to the Community market. This also includes the batteries that are in- or outside the scope of other directives like WEEE or ELV. For example if there are batteries built-in in your EEE you will be required to register as a battery producer and report consequently what you introduce to a local market.

  • Am I responsible for the packaging used for my products?
    If you are the importer in most cases you do have to take responsibility for the packaging and packaging waste that arises as a result of your business activities. The requirements vary however considerably from Member State to Member State. Please contact us for country specific obligations. Note that we are also aquinted with the ‘de minimis’ thresholds that may save you time and money. (Based on the Packaging Directive (94/62/EC))

  • Am I obligated to the Dutch packaging tax?
    If you are an importer you are legally responsible for the reporting and payment of packaging tax in The Netherlands regarding;
    - all packaged products that you import and place on the Dutch market.
    - all packaging material you buy and add to products placed on the Dutch market.
    - all packaging that you dispose of in the Netherlands coming from products outside of the Netherlands.

    All exports (shipments out of Dutch territory) fall outside of the scope of this responsibility. It is also good to know there is a threshold of 50 tonne to be eligible to the Dutch packaging tax in 2010.

  • What is defined as packaging for the Dutch Packaging Tax?
    Our 'packaging tool' may serve to determine what has to be classified as packaging. Note this tool was designed with the Dutch Packaging Tax in mind. Unfortunately the definition of packaging may differ significantly from country to country.

  • What does the ‘Green Dot’ stand for and is it mandatory?
    Green Dot was a Pan European initiative (see www.pro-e.org) to take responsibility of the macro demands. In short, producers have to report and pay fees to the collective whereas the collective system in return takes over the packaging waste collection and recycling services. Starting 2009 it is not mandatory anymore in Germany aiming to accelerate competition. In some other countries the ‘Green Dot’ label is still mandatory.

  • What is a DoC for packaging?
    Declaration of Conformity (DoC) is an audit for the micro demands. The audit is based on the CEN standards defining the Essential packaging requirements (based on article 9 and 10 of the Packaging directive). Packaging that doesn’t meet these criteria is not allowed on the European market since 1998. In short the Essential requirements require continuous effort to create packaging that is lighter, better recyclable and less bad to the environment. To meet the Essential requirements it is highly recommended to use the CEN standards. This reverses the burden of proof of the producer meaning no Member State can refuse your packaging if you use the CEN standards.

    All relevant CEN standards are shown in the picture structured by the ‘umbrella standard':

  • Where does EPR stands for?
    EPR stands for Extended Producer Responsibility. Producers and importers are made responsible for the management of equipment introduced to a local market, including the waste management when this equipment becomes obsolete. To this end, producers have to collect as much obsolete equipment for the purpose of bringing the raw materials back into circulation and also because e-waste may contain hazardous substances. Producer responsibility can be taken either collectively or individually. Typically consumer products are more eligible to collective compliance and selfcompliance is feasible for professional equipment.

  • How is RoHS enforced?
    In the Netherlands in case of non-compliance the administrative law and criminal law apply. Typically minor offences are fined up to € 16.000, - and 1 year imprisonment and penal offences up to € 67.000, - and 6 year imprisonment. This is of course dependant on the gravity of the offence and the intention of the offender. If companies break the law multiple times the enforcement authority may also choose to use media attention.

    However the enforcing authority recognises that it is hard to proof 100% RoHS compliance. When a company admits a product is non-RoHS compliant they are leniant. This shows responsible behavior and adequate monitoring.

  • Do we need a RoHS label next to the X-out wheely bin?
    No, RoHS labels are not legally binding. Even more, enforcers are more suspicious if there is a label. In the end it is the product that must comply, not the documentation or labelling.

    See below for examples of RoHS labels (the second picture shows the Chinese labels)
    RoHS labels