Skip to content
Electronics
Exemptions for electrical and electronic equipment

Exemptions for electrical and electronic equipment

Substances, materials, and material consumption are the primary areas of focus when producer responsibility is used as a regulatory tool for electronics. Therefore, all products dependent on electric currents are generally covered by legislation. There are certain exemptions from the rules, and they are primarily motivated by products being covered by similar producer responsibility legislation, safety considerations, or logistics. Some product groups, however, are exempted for other reasons.

Which types of products and equipment are exempted?

  • Motor vehicles (subject to producer responsibility for vehicles)
  • Batteries and accumulators (subject to producer responsibility for batteries)
  • Equipment manufactured specifically for military purposes or for protection of national security.
  • Equipment designed to be sent into space.
  • Large-scale stationary industrial tools
  • Infected and/or implantable medical devices
  • Certain specific means of transportation
  • Equipment specifically designed solely for the purposes of research and development that is only made available on a business-to-business basis

Elektronik

In the European Network of National  WEEE Registers (EWRN), with the intervention of the European Commission, a number of guidelines have been prepared to understand and eradicate the most common misunderstandings in connection with the product groups of electronics that are exempted from producer responsibility legislation.

In the elaboration of the excemptions below, we therefore refer to these guidelines where relevant.

Exemptions explained

Electrical and electronic accessories purchased and installed in motor-driven vehicles, boats, airplanes and trains such as GPS units, external CD player, navigation equipment, echosounders and screen, refrigeration equipment, radio and sound equipment, however, are not exempt, as such equipment is not an integral part of the vehicle at the time of construction/production.

Note! Waste electronics removed from motor vehicles etc. are managed according to the general rules on management of waste electronics.

Batteries and accumulators are exempt from the WEEE Order, as they are covered by producer responsibility as defined in the Battery Order. Batteries and accumulators are however not exempt from the WEEE Order’s rules on environmental treatment in the event that they are incorporated in waste electrical and electronic equipment or products.

Equipment manufactured specifically for military purposes and associated with either protection of national security, arms, munitions, or war material are subject to an exemption. Examples of exempt equipment are also monitoring equipment manufactured specifically for the Danish Defence Intelligence Service or the Danish Security and Intelligence Service in the form of equipment with integrated monitoring equipment, where these Services do not want the public to have access to the design of the equipment. Equipment, however, that is also available to the public is not covered by this exemption criterion, since it is not intended specifically for military purposes. An example of such equipment may be a radar used in both civil airports and military facilities. Camouflage-colouring of the equipment does not motivate an exemption in itself.

Purpose: To exclude equipment that is never expected to return to earth. Examples: Rockets and satellites. Control and monitoring equipment, etc., which are controlled from the ground, are not covered by this exception.

The definition of LSSIT consists of three specific prerequisites. In detail:
(i) assembly of machines, equipment, and/or components, functioning together for a
specific application (“tools”); (ii) permanently installed and de-installed by professionals at a given place and used and maintained by professionals in an industrial manufacturing facility or research
and development facility; (iii) and large size.

All three prerequisites must be met for the exclusion to apply.

See EWRN guidance: Large-scale stationary industrial tools (“LSSIT”)

The definition of LSFI consists of four specific prerequisites. In detail:
(i) a large-size combination of several types of apparatus and, where applicable, other
devices, which; (ii) are assembled, installed and de-installed by professionals; (iii) are intended to be used permanently as part of a building or a structure at a predefined and dedicated location; and (iv) can only be replaced by the same specifically designed equipment.

All four prerequisites must be met for the exclusion to apply.

See EWRN: Large-scale fixed installations (“LSFI”)

“Medical devices” may be covered by the exemption criterion “Implanted and infected products”.  Infected equipment is single-use electrical or electronic equipment manufactured for ending its useful life as health-care risk waste and as such being hazardous waste under the Statutory Order on Waste. This may be, for example, a pacemaker or electrodes and probes for single-use purposes.

 

Certain specific means of transportation are also exempted under certain conditions.

See EWRN guidance: Means of transport (“MT”)

See EWRN guidance: Non-road mobile machinery (“NRMM”)

This exemption is aimed to exempt professional equipment initially developed in one or few copies and with one specific purpose in connection with research or development and where at the given time the equipment is not a commercial product or placed on the market to a broader range of customers. Thereby, this equipment only exists at a pre-production stage. In other words, it is a prototype of products or equipment assembled for different forms of development tests.

If it incorporates standard equipment that is also used in non-research and development environments this equipment is not covered by the exemption.

In DPA we are happy to help and guide you; we also make decisions when you are in doubt

Shortcuts

EWRN Guidelines: Large-scale stationary industrial tools

Read more details about exemption for large-scale stationary industrial tools

EWRN Guidelines: Large-scale fixed installations

Read more details about exemption for large-scale fixed installations

EWRN Guidelines: Means of transport for persons or goods

Read more details about exemption for means of transport for persons or goods

EWRN Guidelines: Non–road mobile machinery

Read more details about exemption for non–road mobile machinery

EWRN Guidelines: Medical devices and in vitro diagnostic medical devices

Read more details about exemption for medical devices