Too often, waste from electrical and electronic equipment (WEEE) from hospitals and laboratories fails to find its way to the right treatment facility. Alternatively, when WEEE leaves the market as waste or as second-hand equipment, it is often not reported. As WEEE is hazardous waste, though, it may only be collected and processed by companies that have the appropriate permits. They must report on this via the Recupel WEEE report or through BeWeee, if they are not a member of Recupel nor work with an authorised Recupel partner.
This page offers you all information required to properly dispose of, collect and report WEEE from the laboratory and the medical sector.
Voices from the field
Two experienced voices offer us good examples and practical tips.
Rule of thumb: what to do?
Any appliance with an electrical or electronical component is considered to be WEEE
That implies that these appliances must be sorted, collected and processed separately according to WEEE standards, even if they can still be reused or resold abroad. Unfortunately, a lot of WEEE still ends up in the scrap metal, where it does not belong due to its position as hazardous waste. This applies even to large iron appliances which only have a small electrical component. Sometimes, devices disappear unreported, for example via export. Our appliance list provides a handy overview of all EEE, divided into two categories: household and professional appliances.
Devriese: "Every year, we discard about 3,000 appliances. Managing such large volumes allows us to pre-sort them in our own recycling park. It is vital we keep a tight structure and flow, to prevent people looking for other methods to dispose of their appliances."
Only collaborate with collectors, traders and brokers who have the right accreditation
This could be a certified Recupel partner who has signed our charter and, as such, guarantees correct recycling and exhaustive reporting. You can also choose another partner, although you will have to check for yourself whether they have the right accreditations and meet the legal reporting requirements. This information can be found on the website of the regional authorities responsible for waste. If you export abroad, you are required to report in Recupel’s WEEE report, or via BeWeee.
Rogiers: "We trace each of our appliances throughout the entire chain. When we collect them from our clients, we give them a certificate. If it will be recycled, we receive a processing certificate."
What to do with contaminated devices?
Once a device has been cleaned – in whatever way that makes it suitable for reuse with the next patient – it can be handed in for recycling.
Where to take ...
| Professional WEEE | Household WEEE |
|---|---|
| are designed and intended exclusively for use in a professional context, for example: CT scanners, MRIs, centrifuges, dental drills… | can be used both at home and at work, for example: a coffee maker, a laptop, a monitor, a hospice bed, lights... |
You are required to call on an authorised collector, trader or broker (CTB):
| You can call on the free Recupel services: |
| Not sure about the difference between professional and household WEEE? Discover more examples and exceptions. | |
Why does it matter?
When you dispose of electrical or electronic appliances, you are legally obliged to use an authorised collector, dealer or broker (CTB). At least 65% of all appliances placed on the market must be correctly collected for reuse or recycling when they are no longer used. This target is imposed on each member state by the European Union.
Today, Belgium collects almost 60% of WEEE. With this result, we are among the frontrunners in Europe. For the medical sector, the figures are lagging, with a correct collection rate of 35%. That is why correct reporting of the flow of waste from electrical and electronic equipment in the Recupel WEEE report or via BeWeee is vital.
Devriese: 'When you sell an appliance to a buyer who removes the circuit boards and sells the rest as scrap, you introduce risks: that "scrap" may still contain toxic, flammable or explosive components. As a disposer, that means you are no longer legally compliant.'
For people and planet
Discarded electrical and electronic appliances are classified as hazardous waste. Proper collection ensures that they do not end up at a treatment facility which is not equipped for this waste. Moreover, these appliances still contain a wealth of valuable raw materials for recycling.
The discarder
As a company, what should I pay attention to when discarding my (W)EEE?
Requirements
- When is electrical and electronic equipment 'waste'?
As soon as a hospital or laboratory discards an appliance, it is called waste, even if the equipment is subsequently given a second life through reuse. WEEE is hazardous waste and must be transported, collected and processed as such. It should not be treated the way scrap metal or old iron. - The proper authorisations for WEEE
Any company which discards an electrical or electronic appliance is legally required to call on authorised and/or registered entities, namely:
- An authorised or registered collector, dealer or broker (CDB) for hazardous waste;
- An authorised or licensed carrier of hazardous waste;
- An authorised or licensed processor, operating in compliance with WEEELABEX/CENELEC.
- This requirement applies to both household and professional appliances.
- If you engage a collector or processor approved by Recupel, you can be sure that they meet the legal requirements regarding transport, collection and processing. Additionally, they comply with the rules for the regional authorities’ legal reports. Do you call on another party? Make sure to check whether your partner has the necessary permits and meets the legal reporting requirements. You can check this on the websites of OVAM, Bruxelles Environnement and Environnement Wallonie.
- Separate collection of WEEE
As a hospital or a laboratory, you are a waste producer or holder. Thus, you are required by law to treat and collect WEEE separately from other types of waste. This requirement applies to both household and professional appliances. - Waste register
As a company, do I have to register my WEEE?
As a company that produces waste, you are a “waste producer” (Flanders), a “waste holder” (Brussels) or a “producer of hazardous waste” (Wallonia). You are therefore required to keep a register of the waste produced, including the following information:
- amount of waste disposed of (in kilograms), divided by category;
- date of disposal;
- nature of waste and its origin;
- name and address of the consignee of the waste: CDB, producer, reuse centre or licensed processor to whom the waste was shipped.
The register also contains any necessary traceability documents, signed by the person accepting the waste.
The register shall be completed at least once a month and the data included shall be stored for a minimum of five years. Upon simple request, the register shall be delivered to the authority concerned.
Rights
Because of the take-back obligation, when you buy a new similar appliance, you have the right to return your WEEE to the seller, whether that is a distributor, retailer, intermediary or producer. This take-back obligation, known also as an “acceptance obligation” means that producers are responsible for taking back and properly disposing of waste originating from their products. This applies to online purchases as well.
The take-back obligation for old appliances upon purchase of a new similar appliance applies to household appliances as well as professional appliances. For household appliances, this solution must be offered free of charge by the seller. For professional appliances, this solution does not have to be offered free of charge by the seller. For the conditions, contact your supplier or call in a Recupel-approved collector for the collection of your professional appliances.
Tip: you can also use Recupel Pick-up for a one-off collection of your household WEEE. If you need a collection several times a year, you can register as a Recupel point.
Please note: only non-contaminated household appliances will be taken back free of charge. A contaminated appliance must first be decontaminated, or treated as medical waste. If an appliance has been prepared for the next patient, we consider it to be decontaminated. Both processes are the responsibility of the end user.
The carrier
is any natural or legal person who transports waste professionally by road, inland waterway or rail.
Requirements within Belgium
A carrier is responsible for transporting waste by order of someone else (an CDB). A carrier therefore does not decide where to collect the waste or to which destination it will be transported. It is the principal who determines these and is also responsible for the identification form (only available in Dutch).
An identification form must be present during every shipment of waste, except in the case of a limited number of exceptions. The responsibility for its format and content lies with the CDB, or the producer who makes their own arrangements for their waste. The transport of the waste may not depart until an identification form is present.
If you transport WEEE, registration as a waste carrier is mandatory. Both import and export are subject to strict rules. If you want to import or export WEEE, first contact the authority responsible (OVAM, Bruxelles Environnement or Environnement Wallonie). Registration with OVAM is valid only in the Flemish region. Are you driving through Brussels, Wallonia or the European Union? Then it is best to check with the local authorities on what you need to do.
The following actors are excluded from the registration requirement to register as waste carriers:
- The supplier of goods who, in the context of the take-back obligation, of the acceptance obligation, or of voluntary take-back, on the occasion of a delivery of goods, brings empty packaging or discarded goods to their premises or to a collection point for discarded goods.
- The waste holder who, in the context of the take-back obligation, the acceptance obligation or a voluntary take-back, brings the waste back to their supplier of similar good.
- The recycling centre or reuse centre for EEE, which has undergone a visual pre-selection for reusability, transports the waste to a reuse centre for EEE, in light of eventual reuse.
Requirements outside of Belgium
WEEE
The export of WEEE to non-OECD countries is prohibited. You may not export hazardous waste such as WEEE to developing countries, even for treatment.
When exporting WEEE, for recovery or disposal, to countries in the EU or the OECD, a mandatory notification must be made to the competent authorities, which must approve these exports.
- Flanders
- Exporter WEEE (only available in Dutch)
- https://ovam.vlaanderen.be/kennisgevingsprocedure
- Contact: contact form on cross-border transport
- Brussels
- Waste management: your requirements? | Professionals Bruxelles Environnement (only available in Dutch or French)
- contact: wasteshipment@leefmilieu.brussels
- Wallonia
- Requesting an authorisation for the cross-border export of waste - transfert transfrontalier de déchets (TTD) (only available in French)
- Contact: ttd.dsd.dgo3@spw.wallonie.be
EEE
Should the EEE be transferred to another country for processing, it is ensured that the EEE will be treated appropriately under conditions equivalent to those in Belgium. Transfer of used EEE must meet certain criteria:
- Documents
When transferring used EEE (and not WEEE), the holder must be able to present the following documents:
- an invoice and contract indicating that the EEE is fully functional and not intended for reuse;
- a proof of evaluation or testing of the EEE;
- a declaration that the EEE is not waste.
Exception: these documents are not required if the EEE is returned for warranty repairs or reuse by the producer.
- Testing of EEE
For the transfer of used EEE, tests must be conducted to confirm that the equipment is in good working order and does not contain hazardous substances. The results must be documented. - Other documents
Each shipment of used EEE must be accompanied by a transport document and a declaration of responsibility. - Appropriate protection against damage during transport
In the absence of appropriate documentation or protection, the device is considered to be WEEE, leading to an illegal transfer.
Used EEE which does not meet the reuse criteria is collected, transported and recycled as waste.
Please note, that an exception applies in the following cases:
- Electrical or electronic appliances under warranty are returned to the producer or their representative for repair, in light of potential reuse;
- Professional, second-hand, appliances are returned to the manufacturer or their representative in countries where waste legislation allows them to be upgraded or repaired before being reused;
- Used and defective appliances, such as medical devices, are returned to the manufacturer or their representative for analysis of the causes of the defect, if such an analysis can only be conducted by them.
The collector, dealer or broker (CDB)
What is a CDB?
Anyone who collects, trades or brokers waste professionally, must register as a waste collector, waste trader or waste broker. If any of these also take on the transportation of waste, they are concurrently a waste carrier and must apply for registration as a waste carrier as well.
You can register as a waste collector, waste dealer or waste broker through the authorities responsible:
- Flanders: the online portal for Registrations of the OVAM. You will be included in the registry of waste collectors, waste dealers and waste brokers.
- Brussels: Bruxelles Environnement
- Wallonia: obtaining approval as a hazardous waste transporter or collector
| Different roles explained |
The collector is any company (or natural person) that collects waste on a professional basis. The trader is the company that acts as the responsible party for the purchase and subsequent sale of waste. This includes the trader who does not physically possesses the waste. The broker is the company which organises, on behalf of third parties, the disposal or recovery of waste. |
The producer or importer
Requirements
Take-back obligations
Producers are responsible for financing the take-back obligation and waste treatment of their own products, whether they be household or professional appliances. For household appliances, there is a free take-back obligation upon purchase of a similar appliance. For professional appliances, this take-back obligation need not be free of charge and the producer or seller may charge a fee for it.
The associated costs for household appliances are provided for by means of the ‘all-in’ Recupel contribution, including the collection and processing of these appliances. You will find this contribution on your purchase invoice. You can therefore use the Recupel points in various shops or recycling parks to dispose of these appliances.
Where professional appliances are concerned, the producer can provide an alternative financing method. Recupel does not offer direct and free take-back, transport or processing. However, you can call on authorised Recupel-partners to comply with all legal requirements and to ensure that collection and processing is conducted according to the correct rules.
Seperate collection
The producer will have to ensure a separate collection of WEEE in a way that guarantees optimal conditions for the preparation for reuse, treatment and storage of hazardous substances. The storage of WEEE must be done in an environmentally responsible manner, taking into account the following technical requirements:
on an impermeable surface of suitable land with spillage collection facilities and, if necessary, oil and dirt separators;
provided with weatherproof coverage (dry);
cooling equipment is moved manually to avoid damage and run-off of liquids and gasses.
Reporting
Reporting must be done as follows:
- total amount of EEE (in numbers and kilograms) placed on the market in Belgium, broken down by category (household or professional);
- the quantity of WEEE, broken down by category and type (household or professional) which was:
- collected under the take-back or acceptance obligation;
- offered to a registered/licensed CDB;
- offered to a reuse centre for EEE in light of preparing it for reuse;
- offered to a licensed recycler of WEEE.
- the quantities of waste resulting from the treatment of WEEE that were prepared for reuse, recycled, recovered, disposed of in incineration plants or landfilled. If a third party was used for this purpose: see next point (Flanders);
- the names and contact details of the collection, treatment and reuse operators involved, with information on the treatment method applied;
- the total amount of WEEE, its components, materials or substances (in number and kilograms, by category and type) that entered (input) and left (output) the pre-processing and treatment facilities and the recycling or recovery facilities (Brussels)
Producers affiliated with Recupel can do this reporting:
- via Recupel's declaration platform, when reporting on EEE which were put on the market;
- via Recupel's annual WEEE-report, when reporting on the WEEE that was collected.
Non-members fulfil their reporting requirement via BeWeee. Please note that the deadline for reporting is 1 July in Flanders, while it must be finalised by 31 May in Brussels and Wallonia.
Frequently asked questions
About the correct collection of WEEE in the medical sector
Which devices are not included in Recupel’s scope?
Any devices used for research and development (R&D), contaminated appliances and blood glucose meters. Find a detailed overview of devices which are subject to a Recupel contribution here.
How do I find the right partner to dispose of my discarded appliances?
Professional appliances
Companies that collect and transport or trade WEEE (CDB) must register with regional authorities and have the appropriate permits. Once an appliance is no longer in use, it is considered discarded, even if it is resold afterwards. Electrical appliances may not be treated as scrap metal after being discarded. They must be processed in companies equipped with the appropriate installation and treatment processes. In addition, they are required to report their processing results to the regional authorities. Here, you can find our authorised Recupel partners.
Household appliances
Recupel Pick-up allows companies to request a free collection of their discarded household appliances.
Can I appoint a company to collect household and professional appliances together?
Yes, provided they are registered as a collector, dealer, broker (CDB) or processor of electrical or electronic equipment.
As a small hospital, can I request receptacles for the recycling of household WEEE?
Yes, you can contact Recupel to have a pallet box placed. If you fill four 2 m³ pallet boxes on an annual basis, you can become a Recupel point. If the volume you collect is smaller, you can make sporadic use of the free Pick-up service.
Do I have to report my WEEE and where?
Are you a producer or importer of WEEE and a member of Recupel? Then you will receive an annual invitation to complete the Recupel WEEE report. Recupel then takes on the requirements for reporting to the regional authorities.
If you are not a member of Recupel, then you are required to report to BeWeee on the appliances you export or give a second life via reuse or recycling.
Who reports when exporting abroad?
The export of WEEE to non-OECD countries is prohibited. You cannot export hazardous waste, such as WEEE to developing countries, even for treatments.
When exporting WEEE, for recovery or disposal, to EU or OECD countries, it is mandatory to notify the authorities responsible (OVAM, Bruxelles Environnement, Environnement Wallonie). They must approve these exports. Additionally, you must report the numbers of such exports. Recupel members can do this through the Recupel WEEE report, non-members can contact BeWeee to do so.
Can I have large, heavy appliances with small electrical and electronic components recycled as metal and scrap?
No. Every appliance with an electrical or electronic component has been marketed as an electrical or electronic appliance, and must be processed and registered as such when it leaves the market. The rules for processing an electrical or electronic appliance are different from those for processing metal and scrap. The processing of WEEE must be executed by a licensed recycling company.
How can I correctly recycle IT equipment in accordance with GDPR rules?
Data carriers containing personal data must be stripped of this data by a wiping process if they are selected for reuse. This overwrites any existing data so that it is irrevocably deleted. If necessary, a certificate can be issued during the wiping process stating the reference of a device.
If they are not selected for reuse but are processed, the devices are not wiped. Personal data protection is ensured by Recupel's closed collection system. The entire device is destroyed, irrevocably erasing all data.
Do I need to report on the export of WEEE if it is returned to the producer’s parent company abroad?
Yes, this is a common mistake. The same rules apply here as for exports abroad.
Export of WEEE to non-OECD countries is prohibited. You may not export hazardous waste such as WEEE to developing countries, not even for processing.
When exporting WEEE to EU or OECD countries for recovery or disposal, a mandatory notification must be made to the competent authorities (OVAM, Bruxelles Environnement or Environnement Wallonie). They must approve these exports. Additionally, you must report the numbers of such exports. Recupel members can do this through the Recupel WEEE report, non-members can contact BeWeee to do so.
Who is required to report the sale of WEEE via a broker?
Do you collaborate with a broker in electrical and electronic equipment? If so, this company is required to register as a CDB with the regional government, even if there is a chance that the device can be given a second life through reuse. The trader is required to report the export of electronics via BeWeee.
Can I collect and dispose of electrical cables separately?
No, you need a WEEE processing licence to remove electrical cables from a device. Devices must be intact when they are handed in to a processor.