This September, stakeholders in the WEEE (Waste Electrical and Electronic Equipment) sector are awaiting how the results of proposed amendments to the recast WEEE Directive 2012/19/EU will affect them, but how will this affect small to medium producers of electrical equipment?
The amendments to the legislation have been in light of the EU’s waste collection target of 85% by 2016 and underlined by the fact that UK governing needs to synchronise legislation. Furthermore, stakeholders in the WEEE market have called for amendments to be made due to the belief that the true costs of WEEE recycling are not being reflected in the cost of compliance.
What does this mean for smaller producers of EEE?
Currently, smaller producers of EEE are required by law to sign up to a PCS, Producer compliance scheme’ however there has been a call for a de minimis threshold following concerns raised in which the BIS (Department for Business, Innovation & Skills) cite in their impact assessment:
“Small volume producers have made representations through the Red Tape Challenge, the Call for Evidence and ministerial correspondence that the cost and administrative burden imposed by the WEEE Regulations is disproportional to the actual costs of ensuring their products are properly created when they become waste.”
De minimis roughly translated as ‘not enough to be considered’ or ‘minimal things’, will affect producers of EEE who produce less than 5 tonnes of EEE a year rather than being based on financial intake.
This protocol is due to encompass 3,420 producers from a total of 6,000 registered producers in the UK and 3,483 tonnes of EEE equalling 0.2% of total UK EEE.
There are two options being considered for the introduction of this sub-section in WEEE legislation. One is a total exclusion from any need to register and the other which would still involve a flat-rate £30 cost to de minimis producers in order to register with a relevant environment agency. This would entail; Company information, annual EEE placed on the market data split by category and annual WEEE tonnage collected split by product category. The cost of £30 is based on the currently used Batteries Regulation.
Amidst the fact that the reporting system is currently under scrutiny due to a large proportion of WEEE being collected by CROs (Collection and Recycling Organisations) that provide no audit trail, the second option mentioned is likely to prevail no matter which of the three amendments to the WEEE directive are chosen. This will also aid the push for the ambitious targets set by the EU in 2016.
This could be great news for around half of the producers registered on WEEE compliance schemes, saving them on average 10% per tonne recycled through their compliance scheme.
The de minims agreement does not mean however that these smaller producers are exempt from the WEEE directive, far from it.
All producers are still required to comply with the WEEE Directive….so smaller companies who will not be supported by their existing PCS will now be left to make their own arrangements to compliant waste disposal of electrical goods.
Collect and Recycle not only assist in the collection, treatment and recovery of waste electrical goods produced, but also make sure they are able to provide a compliant and traceable service for these customers. They have recently launched a new service named ‘Producer Regulatory information service’ to support those companies that operate in the B2B EEE sector and still require assistance in their reporting obligations as well as any additional recycling commitments they may have towards their customers.
Any small producers of EEE subject to this legislative change in need of a reliable collection service and specialist customer support will benefit massively from their knowledge and service.
Please send any enquiries to Collect and Recycle at: enquiries@collectandrecycle.com
Callum Rees
