Waste

Law 7/2022 · RD 110/2015 · Regulation (EU) 2023/1542

The framework governing the end of life of corporate IT assets operates in two phases. EoL360 centralises, asset by asset, the documentary support for both: the prior reuse-fitness assessment and the traceability of the WEEE fraction’s treatment by an authorised operator.

Two-phase model

In the pre-waste phase, the holder individually assesses reuse fitness before classifying the asset as waste, applying the hierarchy of art. 8 of Law 7/2022 and the distinction between used EEE, reusable components and WEEE established in RD 110/2015.

Only the non-fit fraction enters the waste-management regime. From that point, the producer is obliged to ensure adequate management and to document the complete treatment (art. 20, Law 7/2022). Handing assets to an authorised operator does not, by itself, extinguish this liability: it subsists until the treatment is duly documented (art. 20.2).

Phase 1

Pre-waste · Fitness assessment

EoL360 captures, asset by asset, the technical criteria applied, the individualised assessment outcome and the routed destination (reuse or classification as waste). Without this case file, the decision to route into the WEEE flow lacks documented justification.

Phase 2

WEEE · Treatment traceability

For the fraction that fails the assessment, EoL360 documents delivery to an authorised WEEE operator and captures treatment traceability, closing the initial producer’s liability under art. 20.2, Law 7/2022.

Applicable regulatory framework

Law 7/2022 · Art. 8

Waste hierarchy: prevention, preparation for reuse, recycling, other recovery, disposal. Departing from this order requires documented justification (art. 8.2).

Law 7/2022 · Art. 20

Initial producer obligations: ensure adequate treatment and document the complete treatment. Liability subsists until the treatment is duly documented (art. 20.2).

Law 7/2022 · Art. 108.3.t

Classifies as a grave infringement the breach of the initial producer’s obligations regarding non-hazardous waste management. Applicable where reuse fitness has not been assessed and no case file evidences it.

Law 7/2022 · Art. 108.3.e

Classifies as grave the breach of documentation and recording obligations. A concurrent application is plausible where the documentary support required by art. 20.1 is missing.

RD 110/2015

Specific WEEE regime. Distinction between used EEE, reusable components and WEEE — the axis on which the pre-waste phase operates.

Regulation (EU) 2023/1542

Batteries. Imposes separate handling where the equipment incorporates an integrated battery, without prejudice to the classification of the complete equipment.

Sanction range · Art. 109

Classification	Non-hazardous waste	Hazardous waste
Minor	up to €2,000	up to €20,000
Grave	€2,001 — €100,000	€20,001 — €600,000
Very grave	€100,001 — €3,500,000	€600,001 — €3,500,000

Accessory measures

Beyond the amount: publication of the sanction (art. 118), withdrawal of administrative authorisations and an obligation to restore or remediate. Reputational exposure may exceed the direct economic effect.

Applicable EWC classification

EWC code	Description	Character
16 02 11*	Equipment containing chlorofluorocarbons, HCFC or HFC	Hazardous
16 02 13*	Equipment with hazardous components (mercury, lead, cadmium)	Hazardous
16 02 14	Discarded equipment other than the above	Non-hazardous

Corporate laptops and LED monitors fall under EWC 16 02 14 in the standard case. The classification may escalate to EWC code 16 02 13* where hazardous components are present. The mere presence of an integrated battery does not automatically determine the classification of the complete equipment as hazardous waste.

How EoL360 covers it

Evidence · Pre-waste

Individualised per-asset fitness-assessment case file, with technical criteria applied, outcome and destination. Covers art. 8 (hierarchy) and the RD 110/2015 distinction.

Evidence · WEEE

Capture of treatment traceability by the authorised operator and documentary closure under art. 20.2. The producer’s liability is extinguished once the treatment is duly documented.

Registry enrolment

ZirquloApp, S.L. is registered as a Waste Agent in the Catalan Waste Operator Registry (A-10712, NIMA 0801347760).

Defence before the authority

The generated case file constitutes evidentiary support against a regional sanctioning procedure under art. 108.3.t and concurrent exposure under art. 108.3.e.

Evidence compliance from the very first retired asset

We show you how EoL360 documents every phase of the process for your organisation.

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