Some foreign module manufacturers offer their customers “AEEA compliance” as a service. This is often done by registering the manufacturer in the Dutch WEEE register. The Dutch importer (the “producer”) and the manufacturer both believe that in doing so the manufacturer takes over the AEEA responsibilities.
However, the Dutch government recently declared that a manufacturer cannot take over the AEEA responsibilities from the Producers (importers). This implies that a registration of the manufacturer in the WEEE register is incorrect. The importers (Producers) remain responsible for their own correct registration. This also holds for the obligation of having an “appropriate financial arrangement” in place.
However, a manufacturer is allowed to offer the execution of the AEEA obligations as a service. In this case, the Producer (importer) can still rest assured: his responsibilities are taken care off. The difference is that in this case all is arranged in line with the Dutch AEEA regulations.
Please contact us if you want to know more.