How does compliance with Royal Decree 110/2015 on the management of WEEE in Spain affect the daily work of installers?

Installation companies, in their routine tasks of installing and maintaining various types of systems, both domestic and commercial/industrial, frequently act as retailers or distributors of EEE, serving as the final link in the supply chain to the end customer.

They may also subcontract for the product retailer, meaning that even without a direct commercial relationship with the end customer, they install, maintain or repair products sold by the retailer and purchased by the customer.

In both scenarios, they are subject to certain obligations imposed by regulations regarding the packaging of supplied products and the collection of those withdrawn from the market, which must undergo proper management.

What responsible practices do installers associated with the entity implement to ensure proper uninstallation of equipment and subsequent management of WEEE?

Typically, WEEE is removed ensuring it can be safely and completely delivered to waste managers.

When dealing with air conditioning and refrigeration equipment containing fluorinated gases, there are two additional considerations that require careful attention. Firstly, WEEE is classified as hazardous waste. Secondly, it is essential to recover fluorinated gases from both the installation and the equipment itself if it cannot be sealed with the incorporated gas.

In such cases, installers must obtain additional authorisation in line with RD 115/2017, which regulates the marketing and handling of fluorinated gases and related equipment. This includes certification for professionals handling these gases and sets out technical requirements for facilities involved in activities emitting fluorinated gases.

How are packaging and wrapping materials managed in installed equipment? Are they recycled through authorised managers or disposed of along with other waste?

In some cases, the company itself removes the packaging and deposits it in designated bins or collection points. However, particularly at the household level, owners of small-sized equipment often keep the packaging because, if they need to make warranty claims, returns or exercise their right of withdrawal, the product must be returned in its original packaging.

Do installation companies associated with the entity receive specific training on waste management and the importance of recycling?

Especially for companies involved in installing and maintaining air conditioning and refrigeration systems, they receive specific training on properly managing hazardous waste arising from their professional activities.

What specific initiatives or programmes do associated professionals implement to promote the reuse of appliances or the repair of equipment instead of discarding them?

For consumers, recent amendments to the Consumer Protection Law, which became effective in January 2022, have introduced measures to encourage equipment repair. These include extending warranty periods and mandating manufacturers to supply spare parts for a longer period after a product is discontinued.

Moreover, since most electrical and electronic appliances supplied by installation companies retain significant value, customers often prefer repair over replacement, especially when the cost difference is substantial.

However, regulations occasionally encourage equipment replacement before the end of its lifespan to promote upgrades for safety, energy efficiency or environmental reasons, such as the phase-out of specific refrigerant gases.

In commercial and industrial domains, the installation owner typically favours repair over other options, with few exceptions.

Do you think that raising awareness among installers about the management of WEEE could improve the current situation of these wastes?

All efforts to promote training and awareness among professionals and companies in the sector should be seen as positive. They will contribute positively to installation companies developing policies that enhance the collection and recycling rates of EEE they supply or install.

Properly compensating the economic costs associated with implementing these measures for professionals can also help achieve this objective.

What are the main challenges that AGREMIA faces in terms of the proper management of WEEE?

Our focus is on providing appropriate guidance and information to installation companies, especially newcomers to the sector, regarding their environmental responsibilities. We also facilitate their engagement with organisations like Fundación ECOTIC Clima, which assist them in meeting these obligations by providing the necessary means to manage waste resulting from their professional activities effectively.

What measures or improvements could be implemented to enhance the management of WEEE in the installation sector?

As mentioned, continuing efforts in information dissemination, training and raising awareness are crucial, especially for professionals and companies entering the sector each year.

Additionally, adopting technical measures to facilitate the collection and delivery of waste to waste managers is essential. It is important to note that freelancers
and other professionals often lack infrastructure to store waste while waiting for pick-up by waste managers.

For electrical or electronic waste that may be combined with other types of waste, such as refrigeration and air conditioning equipment containing refrigerant gases requiring simultaneous collection, we propose that both types can be delivered to the same waste manager, eliminating the need for separate deliveries to differently authorised managers.

Regarding hazardous waste, we suggest regulations allow installers to transport such waste directly to waste management facilities, similar to their current practice of transporting it to their own facilities for temporary storage before collection by waste managers or transporters.

Lastly, as mentioned earlier, adequately compensating the costs associated with complying with legal requirements would undoubtedly encourage installation companies to diligently meet these standards.