Manufacturer or importer of electrical appliances? Check the UPV

Do you put electronic or electrical appliances on the Dutch market, and are you the first to do so? If so, you may also be responsible for the product when it becomes waste. You must then ensure that your appliances are processed and recycled in an environmentally friendly way.

Extended producer responsibility (UPV) ensures that manufacturers or importers remain responsible for their products even after the customer no longer uses them. If the UPV applies to your product, you need to consider additional costs and rules.

UPV: for which products?

Do you produce or import electrical or electronic products? And are you the first to bring these onto the Dutch market? Then this UPV applies to you. Even if you sell from abroad directly to customers in the Netherlands.
What exactly is an electrical or electronic device? In short, all products that work with or by electricity. Think of appliances with a plug, battery, or battery pack. Like a lamp, fridge, hoover, but also a mobile phone. There are also products where electricity is an afterthought, such as a teddy bear with sound or an electrically adjustable desk. All these items fall under the UPV Electrical/electronic equipment. There are exceptions, such as electric cars or pacemakers. So always check in this downloadable pdf (in Dutch) whether the UPV applies to your device.

Electrical device or electrical component?

Is only part of the product electrical? Then the UPV does not apply to the whole product, but only to that electrical part. Think of a chip, a transistor or the motor in an electric toy car. You must be able to remove the part easily, without damaging the device. Can you not do that? Then the UPV does apply to the whole product.

You need to do this

If the UPV applies to you, you are obliged to join the producer organisation foundation OPEN. You do this by registering with the foundation. The OPEN foundation works as a representative of all producers of electrical and electronic appliances. They arrange all UPV obligations for you. From registering and reporting to the National (W)EEE Register to collecting, sorting, and processing discarded appliances.

This is how it works

To ensure that the collection process runs smoothly, the OPEN foundation works together with municipalities, waste recycling centres, sorting centres, and processors. It goes like this: most electrical and electronic waste comes in via waste recycling centres. From the environmental centres, it goes to one of the 21 special sorting centres. There, they separate batteries and hazardous products from the rest, among other things. If a sorting centre can no longer do anything with the remaining electrical or electronic waste, it goes to a processor. It recycles the materials. This way, waste materials can be reused.

Paying contribution

So the foundation and its network do most of the work for you. The only thing you do yourself is to report to the foundation every year what appliances you bring onto the Dutch market. In numbers and in kilos. Based on this information, you pay the foundation an amount of money for collecting and processing the discarded products. The OPEN foundation uses fixed rates for this, which are redefined annually.

Avoid warning or fine

Registering with the OPEN foundation is not an option, but an obligation. The foundation takes action if it turns out that you are not registered but do have producer responsibility. For example, they can make an official notification to the Inspectorate for the Environment and Transport (ILT). ILT can issue a warning or fine to businesses that fail to register and thus fail to comply with the UPV.

In doubt about whether you need to comply with producer responsibility? Email the OPEN Foundation at producenten@stichting-open.org or ask them by phone, at 079 7600 630.