A warm welcome to Recolight's first e-newsletter. We will be publishing this newsletter on a regular basis to keep you up-to-date and informed about Recolight's operations and future plans. When we launched the Recolight Compliance Scheme in January 2007 our stated aim was to offer practical solutions to WEEE compliance to support the Lamps industry. In particular, we wanted to offer solutions that would minimise operational costs and enhance customer service, but also encourage good waste collection levels. So far progress has been good. We have recruited a strong list of producer members and developed an effective and robust infrastructure.

However, our plans don't stop there, and our aim is to constantly improve and strengthen the Recolight offer. This newsletter will tell you about our recent news and future plans. We are also keen to hear your views through our "Soapbox" feedback function.

Eddie Taylor, Chief Executive, Recolight

Our philosophy at Recolight is to help our members and all users make the best of WEEE, but in a way that adds value to their business and to their customers whilst remaining cost efficient.

One approach would be to go for minimal WEEE compliance in which, for example, all transactions would be strictly vetted to determine whether they were producer responsibility or user responsibility. Given the multi-level supply chain for lamps and the similarity of lamp products this can only be a false economy for lamp producers and users alike, with high product vetting costs and confused, frustrated customers.

The Recolight scheme has chosen a different approach; one which recognises the nature of the lamp market and has therefore been designed to make it simple for all users of lamps to return them at end-of-life for responsible recycling treatment to WEEE standards. This means skipping the vetting steps and accepting more lamps back under producer responsibility than the Regulations strictly require but gives all parties involved the benefit of a simpler system for them and their customers to use  and ultimately lower costs and higher environmental performance.

The Recolight Scheme, for instance, provides in its standard service:

• access to the RecoNet collection network or pick-ups at site (minimum volumes apply);
• containers where appropriate and transport to a treatment centre;
• national help-desk for customer service enquiries, collection requests etc
• recycling treatment and recovery of raw materials;
• compliance scheme management including registration of Producer members;
• WEEE statutory reporting to government;
• marketing communication and promotion.

If you are signing up for compliance services, ensure you are comparing service and costs on a like for like basis. Recolight is also able to accommodate particular requirements for users, outside its standard service, although there may be some extra costs involved for the user.

WEEE has been a major change for everyone - but we at Recolight believe we offer the best and most cost-effective approach for the long term benefit of the industry, and one that that will also achieve substantial environmental gains for all participants.

The Recolight website design is in the process of being updated to provide members and all user groups with a wealth of information and help. The dedicated user area is an outstanding resource for users, providing them with a platform to raise questions and queries. Features such as on-line ordering of collections also streamline processes to make them cost efficient, and help Recolight users to maintain quality customer service levels.

On a regular basis we will also highlight an area of the Regulations and provide our understanding of its implementation, starting this month with:
Electrical and electronic equipment that is part of another type of equipment
BERR Guidelines document para 12

"12. The WEEE Directive excludes EEE that is part of another type of equipment that does not fall within the scope of the WEEE Directive. Examples are lighting or entertainment equipment for use specifically in vehicles, trains or aircraft. Equipment specifically for use in vehicles may, however, be subject to the End-of Life Vehicles (ELV) Directive".

Recolight's understanding:  

Our understanding is that, if the lamp is unique to the vehicle in question, be it a train, plane, ship or MoD vehicle, and particularly if it is "sealed for life" i.e. no replacement of lamps during life, then it is definitely out of the scope of the regulations.

However if the lamp is a standard product, the same as those used, for example, in offices, shops or factories, as well as in vehicles (and other equipment not covered in the scope of WEEE) and that it is regularly replaced on a maintenance basis during the longer life of the product it is installed in, then it is included in the scope of the Directive.  

In some circumstances a possible exception to this rule is ships. In many cases the products (lamps) will in effect be exported in the sense that maintenance replacement could take place anywhere in the world and exports are out of scope of the UK Regulations. It will be necessary to demonstrate that the maintenance takes place outside of the UK but in those circumstances Recolight can advise organisations on how best to proceed.