RESOURCE CENTRE

All resources related to the WEEE regulations, including downloads and useful links.

The Recolight Resource Centre provides all you need to know about WEEE compliance, recycling and the regulations.

  • All about WEEE and the regulations.
  • Lighting in scope of the WEEE regulations.
  • Lighting Producers’ WEEE obligations.
  • The lamp recycling process and how Recolight manage this on behalf of our Lighting Producer Members.
  • A glossary of terms for all things WEEE.

Should you not find your answer in the above section have a look at the

  • FAQs for lighting producers and business end users.

The last section of the Resource Centre includes

  • Download section for Recolight and Environment Agency documents.
  • Useful links for Businesses and Lighting Producers.

If you still can’t find the information you’re looking for, contact us.

Householders will find information about recycling low energy light bulbs on the pages for Consumers.

HOW WE RECYCLE

 

The Recolight recycling process

Recolight takes on the responsibility of its producer members for ensuring there is an infrastructure for the collection of WEEE lamps and to finance the costs of efficient, reliable and environmentally sound solutions for Lamp recycling.

 

Working with recycling and logistic operators

  • Our recycling and logistics operators are sourced to conform to the relevant statutory requirements of the Regulations and Standards.
  • Our purchasing and tendering process specifies the criteria to which potential Operators will have to conform. We seek Operators with the highest quality standards and certification to the relevant parts of ISO 14001 assists the selection process.
  • Regular audits are undertaken with appointed operators, which are comprehensive and comply with the requirements of the UK WEEE Regulations and any other regulations set out by relevant parties such as DEFRA or The Environment Agency. This is to make sure that the highest standards of recycling and practices are adhered to.
  • We finance the costs of collection and recycling from Designated Collection Facilities – (DCFs) and Commercial Collection Points – (CCPs) as required by the Regulations.

 

Recovery rate

The WEEE regulations set a target of 80% for reuse of materials recovered during lamp recycling – The Recolight recycling recovery rate is over 90%.

 

Recovery of lamp material

The materials recovered from the various processes used in the industry can be used in a number of different ways.

  • It is feasible to recover the lamp phosphor powders, particularly the triphosphor type, and re-use them to make new lamps.
  • The mercury collected, when purified to the right level, may also be used to make new lamps or it may be used in other industrial processes.
  • The crushed glass can be mixed with a new glass melt for a variety of applications, from furnace linings to making new lamps, though in this latter case the purity level of the recovered glass becomes very important.

 

LED recycling

LEDs currently represent less than 1% of the lamp waste stream. Because to many end users they are indistinguishable other lamps, they are collected with other GDLs and would go through the normal processing route, where the recovery rate is 80%.

Current LED retrofit lamp recycling process

The Environment Agency (EA) has pragmatically taken the position that LEDs and GDLs can be co–collected, despite existing requirements that hazardous and non-hazardous waste should be separated.

Co-collection allows compliance schemes like Recolight to ensure the waste is collected so that, in the longer term, when the percentage of LED in the waste stream rises, we already have a culture of collection.

In principle, LEDs can be recycled with other WEEE as they do not contain mercury, and are therefore more similar in nature to other WEEE than to GDLs. But they should be treated as mercury bearing lamps where they are co-collected; as there is a risk they may have some mercury contamination. This is because breakages in general containers will cause some fugitive emissions.

This position is reinforced within the CENELEC waste lamp treatment standard.  However, with the involvement of Recolight in the development of the standard, an additional provision was included. This states that LEDs can be treated through a separate process, if collected as a single LED-only load (and verified through the audit trail that confirms no mercury contamination). This allows the standard to be relevant now and also in the future when the level of LED waste lamps is expected to grow.

The principle recyclates arising from GDL and LED retrofit recycling are:

  • Glass
  • Aluminium and circuit boards
  • Phosphor powders containing rare earths and mercury
  • Plastics

Challenges of recycling LEDs

The diversity of design and construction of LEDs presents additional challenges to their recycling. LEDs contain rare earths, but there is currently no methodology to recover these as they exist in such minute quantities.

Retrofit LED tubes can cause an issue for some lamp recycling equipment because they don’t break up in the same way as a normal tube.

They can be separated and manually dismantled like many luminaires, or they can be sent to a general WEEE processing plant.  Due to their size, small retrofit LEDs can sometimes slip through a general WEEE shredder without being shredded.

These are currently considered to be relatively minor issues and because of the time it takes for LEDs to reach end of life, there will be a time delay of up to 10 years in which to develop any specific treatment technology that may be required. Work is already underway.

Recycling luminaires with both traditional and LED sources

Today, LED Luminaires with their relatively recent introduction to the lighting market, have almost zero presence in the waste stream. Dedicated recycling processes are not currently used by Recolight’s suppliers.

Most luminaires, regardless of the technology inside, are treated in the same way as most other most other non-hazardous general WEEE. This includes luminaires based around traditional lamp technologies such as fluorescent and High Intensity Discharge (HID) lamps.

Assuming the luminaire is not suitable for refurbishment and re-use, the objective of treatment is to separate the device into its’ constituent materials (plastics, metals, etc).

Re-use for new products

The parts that are deemed not suitable for recycling are then targeted for use to generate energy from heat by burning, or, failing that, into landfill.

As the luminaires progress through each stage of the process and are split into their increasingly pure constituent materials, contaminant materials become released.

Where the quantities of those contaminants are significant in quantity and deemed to be recyclable, they will be gathered and sent for further processing.

For example:

  • Significant quantities of released cement could be sent for processing as construction materials or aggregates.
  • Wood and card could also be sent to be sent to appropriate specialist recyclers.
  • Where the materials are not deemed significant enough in quantity or recyclable they can be sent for energy production through incineration or, as a last resort, to landfill.

 

The future of LED Luminaire recycling

In the longer term, the convergence of lamps and luminaires into LED luminaires will mean one larger unit will be treated in the future.

Investment in new treatment technology must take careful note of these developments in the lighting market.

The rate for separately collected luminaires in the UK is currently very low compared to the lamp recycling rate.

 

Year                Lamps                 Luminaires

2012                39.5%                   0.59%

2013                52.8%                   1.95%

2014                29.3%*                 1.87%

2015                43.6%                   4.4%

Recolight launched its luminaire compliance service in 2013; this has helped to double the luminaire collection rate from 2013 to 2015.  Many luminaires continue to be returned as scrap, and not properly reported and recycled as WEEE, and this contributes to the low recycling rate.

*The reduction in the lamp recycling rate for 2014 was expected, given that for the first time, the 2014 data includes LED lamps as well as Gas Discharge Lamps. With very large quantities of LEDs being sold – but very few being returned as WEEE, the inclusion of LEDs in the calculations has inevitably reduced the rate significantly. 

THE WEEE REGULATIONS

Reuse and recycling of waste Electrical and Electronic Equipment

Implemented in 2007, the Waste Electrical and Electronic Equipment (WEEE) Regulations set about increasing the reuse and recycling of waste Electrical and Electronic Equipment by reducing the amount of WEEE going to landfill.

The regulations aim to improve the environmental performance of businesses that manufacture, supply, use, recycle and recover EEE. You may have obligations under the WEEE Regulations if you are a business which sells electrical or electronic equipment.

The WEEE directive covers a wide range of electrical and electronic products including TVs, DVD and video recorders, IT equipment, medical devices and monitoring and control instruments.

The Regulations affect all parties in the electronics industry in one way or another but the primary groups are producers who become responsible for financing the end-of-life treatment of their products, and distributors who become responsible in some cases for taking-back end-of-life products when new products are purchased.

The regulations require all producers of electrical and electronic equipment to join a compliance scheme which manages the process on their behalf, and schemes such as Recolight – which works on behalf of the lighting industry – provide these services free of charge to the end user.

Under the Regulations the producer funds its share of the collection, recycling and environmentally friendly disposal. But it is the end user that has ultimate responsibility for making sure the product is recycled when it reaches end of life.

2012 WEEE Directive recast and UK WEEE Regulation update

The EU published the WEEE Directive Recast in July 2012.

All EU Member states had 18 months to implement the changes. The UK government published the updated WEEE regulations in December 2013 and it was implemented in January 2014.

Along with the changes to the WEEE directive, the UK Government took the opportunity, through the Government’s Red Tape Challenge, to implement a system in the UK that is fair to all.

Key changes to the EU WEEE directive and UK WEEE regulations

READ MORE

Key changes to the EU WEEE directive

Member States recycling targets

There is a change to the targets given to Member States on the level of collections of WEEE.

  • Previously there was a target of 4Kg/head of population, which the UK has comfortably exceeded.
  • This has moved to a percentage of the average weight of the three previous years’ put on market figures.
  • The target will start at 45% for 2016, rising to 65% by 2019.

The Member State target from 2016 applies to all WEEE – whether from household or non-household sources.

Move to an open scope

Products in scope of the directive remain the same, but will move to an open scope in 2019. This means a wider range of electrical and electronic equipment will be included. However:

  • Incandescent lamps will remain excluded from the directive.
  • Household luminaires will come into scope in 2019
  • Photovoltaic panels were brought into the scope from 2014.

LED lamps

LED lamps are already in scope within the UK.

Very small WEEE collections by retailers

Retailers with floor space of 400m2 or more dedicated to the sale of EEE, will be required to collect very small WEEE – defined as up to 25cm in any one dimension. This will therefore include a requirement to separately collect waste CFLs, unless they choose to join the Distributor Takeback Scheme.

 

Key changes UK WEEE regulations

The following is a summary of key changes, more detail can be found on the Recolight Blog

The WEEE regulations demonstrate that the government is fundamentally committed to changing the household WEEE system.

Changes implemented in January 2014:

► Gas Discharge Lamps and LED light sources in the same category.

This was a common sense approach which recognises the change taking place in the lighting market.  It also reduced the risk of an unfunded fluorescent lamp waste stream in the years to come.

► Change to the household WEEE system.

The government has implemented a system incorporating collection targets and a compliance fee alternative if targets are not met by a Producer Compliance Scheme.

► De minimis threshold of 5 tonnes

In the regulations there is no requirement for a producer of EEE to join a compliance scheme if their put on market is less than five tonnes a year.

For more information about the De Minimis and the options available, please go to our page for Small Producers.

The non-household (B2B) WEEE system remains largely unchanged.

Recolight will continue to provide a luminaire collection and recycling service across the UK.

Links to WEEE directive and regulation documents

Joint Trade Association lobbying for a fair approach

Recolight supports the Joint Trade Associations (JTA) and have lobbied for a fair approach to the regulations.

The JTA is composed of nine trade associations, their members include:

LIGHTING IN SCOPE OF WEEE REGULATIONS

All lighting in scope of the WEEE regulations is covered by the Recolight compliance scheme: providing an integrated WEEE compliance service for Lighting Producers and a complete recycling service for

lighting in scope of WEEE regualtions

  • all GDLs
  • LEDs
  • Business luminaires

 

Lamps – category 13

Gas discharge lamps:

  • Straight fluorescent tubes
  • Circular fluorescent tubes
  • Compact fluorescent lamps
  • High Intensity Discharge lamps
    • High pressure sodium HPS or SON
    • Low pressure sodium SOX lamps (street lighting)
    • Metal halide
    • Ceramic metal halide
    • Mercury
    • Xenon
    • Induction

Most of these lamp types are used in both household and non-household applications. All gas discharge lamps are identified under the Hazardous Waste Regulations as hazardous waste.

Additional guidance for the:

LEDs

  • LED retrofit lamps
  • User replaceable LED modules – eg Zhaga modules

 

Lighting Equipment – Category 5

  • Traditional luminaires
  • LED luminaires
  • LED street lighting

A Luminaire is a complete lighting unit consisting of a lamp or lamps and also the parts which help to position, protect or connect the lamps.

Our Luminaire collection and recycling service is provided for our members obligated waste.

Lighting products not in scope of the WEEE regulations

  • Incandescent lamps (eg GLS, halogen)
  • Household luminaires

are not in scope of the WEEE regulations, and not collected by Recolight.

DUAL USE CLASSIFICATION – OF WEEE LIGHTIG EQUIPMENT AS B2B OR B2C

Government guidance on how Producers should decide if products are classified as Household (B2C), or Non-Household (B2B).

Link to the EEE scope guidance published by the EA

Previously the approach to classification as B2B or B2C was largely based upon the route to market – sales through retailers were B2C, and other channels were B2B. That has now changed. Producers should now use the nature of the product as the basis for the decision.

READ MORE

Government guidance: How to correctly identify B2B and B2C EEE & WEEE

Products that are designed solely for businesses should be classified as B2B. Those that are designed for consumers or for both businesses and consumers should be classified as B2C.

The Government guidance includes general principles, and then specific examples to show how those principles should be applied for each of the different categories of equipment.

It is for each Producer to make their own assessment of their products, using steps 1-3 in the Government guidance. It should be noted that guidance on lamps and luminaires inevitably diverges: lamps are generally more generic and interchangeable than luminaires.

Recolight lamp and luminaire classification advice

Our advice for producers has been written in consultation and agreement with the Lighting Industry Association. The Recolight and LIA advice are both fully aligned to the BIS guidance.

Luminaires (category 5)

The guidance states “B2C luminaires aren’t currently covered by the WEEE Regulations so dual use luminaires are out of scope until 2019. An example of a dual use luminaire is a downlight designed to take a GU10 or MR16 lamp.”
We recommend that you classify luminaires (both traditional, and LED integrated) as B2B but the following are examples that could be considered as ‘dual use’.

  • Downlights and spotlights of a domestic scale
  • Batten fittings
  • Domestic scale decorative fittings
  • Corridor/bulkhead luminaires of a domestic scale
  • Any luminaires currently considered as B2C

Scale typically refers to the size of fittings.
The above products could all be regarded as dual use, and therefore B2C. This therefore takes them out of the scope of the WEEE regulations until 2019. As a result, they are not subject to WEEE and should not be reported on the black box. Note that all emergency luminaires should be classified as B2B.

Gas Discharge Lamps and LED Light Sources (category 13)

The guidance states “The majority of lamps are designed and capable of dual use so should be classified as B2C. Classify as B2C gas discharge lamps, LED light sources (lamps) and sodium lamps (includes retrofit and non-retrofit lamps). Classify as B2B floodlights for stadiums and lamps used in cinema projectors.”
We recommend that you classify all lamps (both traditional and LED) as B2C except the following:

  • Lamps for use in stadium lighting
  • Xenon and LED cinema projector lamps
  • Any similar lamps designed specifically and solely for industrial applications

As a reminder, all incandescent lamps remain out of scope of the WEEE regulations.

Models must be either B2B or B2C

It is important to note that you must classify a product either as B2C or B2B. You cannot split your data to record the same product as partly B2C and partly B2B. This is a change from the previous system, in which it was possible to record a proportion of product as B2B, and B2C.

Interplay with the Energy Labelling Regulations

The Government has confirmed that classifying dual use products as household for the purposes of the WEEE regulations does not mean that those products necessarily need to comply with the energy labelling regulations. The scope and applicability of the energy labelling regulations is not influenced by classification decisions under the WEEE regulations.

Dual Use and the visibility of WEEE charges

On 25th December 2015 the WEEE regulations were changed to allow Producers to show WEEE fees as a separate line item on invoices, unless the products are sold direct to consumers.  It is important that each Producer takes their own decision if, and to what extent, to make WEEE fees visible in this way.

Regulation 51 used to read:

A person must not show a purchaser at the time of sale of new EEE the costs of financing the collection, treatment and environmentally sound disposal of WEEE from private households.

Regulation 51 now states:

A producer or distributor must not show a person, who purchases EEE otherwise than in the course of a business at the time of sale of new EEE the costs of financing the collection, treatment and environmentally sound disposal of WEEE from private households.

LIGHTING PRODUCERS’ WEEE  OBLIGATIONS

The WEEE Regulations state that:

“Producers of electrical and electronic equipment (EEE) are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users.”

You must join a Producer Compliance Scheme which will take responsibility for financing the safe disposal of your share of products at end-of life.

You are classed as a producer if you put a product in scope of the WEEE regulations onto the UK market.

This applies to all companies who:

  • Manufacture and sell electrical and electronic equipment under their own brand.
  • Resell, under their own brand, equipment produced by other suppliers.
  • Import electrical and electronic equipment on a professional basis into an EU Member State.

 

If you put on market less than five tonnes in a calendar year, you may alternatively register directly with the Environment Agency.

Recolight will fulfil its Members’ WEEE recycling obligations.

    • Producers are required to mark all EEE put onto market with the crossed out wheelie bin symbol, this is to encourage its separate collection at the end of its life.
    • The black line under the bin is used to identify products put on market after 2005.
    • Information must also be made available to treatment facilities in respect of new types of EEE put on the market.

Reporting to the Environment Agency

Your put on market data must be submitted to your PCS who will then send it to the relevant environment agency. At Recolight this is done through a WEEE Black Box online reporting system.  This automatically calculates your monthly invoice.

Because reporting is per lamp or luminaire put on market this means you have no hidden costs and can forecast what you will be charged each month.

The regulations require that you also make an annual declaration – this is a summary of all your monthly declarations.

WEEE Regulation documents can be found in our download section

RECOLIGHT GLOSSARY OF WEEE & LIGHTING

 

ATF – Authorised Treatment Facility. In order to treat WEEE, an ATF will need to put in place the necessary equipment and processes that allow the WEEE to be treated to the required standard and in a way that does not cause harm to the environment, workers or people living nearby. A site that is appropriately licensed to treat WEEE is known as an Authorised Treatment Facility (ATF) for WEEE.

AATF – Approved Authorised Treatment Facility means a site which has the appropriate authorisations and approvals to carry out treatment of WEEE, as set out in WEEE Regulation 60. Approved Authorised Treatment Facilities (AATFs) are able to issue evidence of WEEE treatment and recovery. This evidence is required by Producer Compliance Schemes to show that they have met their obligations under the WEEE Regulations.

Approved Exporter – an exporter who is approved under WEEE Regulation 60.

Commercial Collection Points (CCPs) refer to a location, (other than DCF’s), registered in the Recolight process, where significant quantities of WEEE are collected prior to transportation to an AATF. Sites may be classified as ‘open’ or ‘dedicated’, the latter having access restricted to the site owner’s business.

Collection & Recycling Service Organisation (CRSO) is another term used for a Producer Compliance Scheme and is used across the EU.

Designated Collection Facilities (DCFs) –  any establishment or undertaking carrying out collection operations in respect of household WEEE and which is approved by the Secretary of State under Regulation 70.

Distributor Takeback Scheme (DTS). A distributor of EEE has an obligation to accept household WEEE free of charge from a customer if they sell a like for like product. To fulfil this obligation, the distributor can join the DTS. The DTS provides funds to Household Waste Recycling Centres (HWRC), therefore members of the DTS can direct customers to their local HWRC.

Electrical and Electronic Equipment (EEE) – equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex 1A of the EU WEEE Directive EC 2002/94 and designed for use with a voltage rating not exceeding 1000 Volts for alternating current and 1500 Volt for direct current.

Gas Discharge Lamps pass an electrical current through an atmosphere of mercury or sodium to produce light via an electrical discharge. Discharge lighting occurs naturally as lightning. The passage of electrical current through the atmosphere (mainly nitrogen), ‘excites’ the nitrogen atoms to give out a bluish-white light during that split second of the discharge.

Examples of gas discharge lamps include:

  • fluorescent tubes
  • compact fluorescent lamps
  • metal halide lamps
  • mercury blended lamps
  • high pressure sodium lamps
  • low pressure sodium lamps

GDLs form category 13 in the WEEE regulations.

Lighting Equipment/Luminaires: are used as a means of spreading or controlling light and are to be classified in category 5 of the UK WEEE regulations.

Historical WEEE – WEEE arising from products which were placed on the market before 13th August 2005.

Member – A producer which has joined the Recolight Scheme. This is the same as a Participant, where ‘participant’ represents the appropriate contractual language.

Non-household obligated waste – Non-household waste is obligated when a Recolight member supplies new product which displaces old product on a like for like basis, and where the waste was originally supplied before 2005 (does not bear the crossed wheelie bin symbol.)  Non-household waste is also obligated when a Recolight member’s products which bear the crossed wheelie bin symbol reach end of life.  In both situations, the holder of the waste does not have the right of free uplift from business premises.  Instead, Recolight has a duty to set up a system to collect the waste.  In the case of lamps, this is the Recolight open network of waste lamp collection points.  In the case of luminaires, Recolight has established a network of 80 waste luminaire collection points.  Recolight has a duty to finance the recycling of waste delivered into this system.

Operators – any Logistics companies or Recyclers (who may have a logistics operation) who will, under contract to Recolight, collect, transport, store, recycle and dispose of waste relating to their activities and in accordance with the relevant regulatory requirements.

Participant – a Producer which has signed up to join the Recolight Compliance Scheme and thereby passes their obligations under the WEEE Regulations to Recolight in return for financial subscriptions being paid to the Scheme. This is the same as a scheme Member.

Participation Agreement  – The Agreement which all Producers enter into in order to become a member/participant of the Recolight Compliance Scheme. The Agreement lays out the terms and conditions of participation including how the funds shall be raised to finance the collection and recycling of WEEE Lamps.

A Producer is anyone who:

  • manufactures and sells electrical and electronic equipment under his own brand
  • resells, under his own brand, equipment produced by other suppliers
  • imports electrical and electronic equipment on a professional basis into a Member State

Producer Compliance Scheme  (PCS) –  a legal arrangement to permit the passing of the Producer’s Obligations incurred under the WEEE Regulations to a separate legal body – the Compliance Scheme. This body will then arrange the collection, recovery and recycling of WEEE streams on behalf of its registered Producers (see Participants) to meet their aggregated Environment Agency obligations as detailed within the WEEE Regulations.

Put on market – Producers of EEE must declare their put on market units to the environment agency. The term put on market is used to capture products that are given away, used as samples and also sold.

Recovery – a range of activities as defined (by 75/442/EEC, Annex IIB). It does not mean ‘collection’.

Recycling – processing used materials in order to create new materials or products

Reuse – the utilisation of products or materials in their original form.

Separately collected waste – WEEE must be collected separate from other waste.

Treatment – the activities outlined in regulation 31 of the WEEE regulations

WEEE – Waste Electrical and Electronic Equipment including all related components, sub-assemblies and consumables, which are part of the product at the time of discarding.

WEEE from private households – WEEE that comes from private households, together with that from commercial, industrial, institutional and other sources which, because of its nature and quantity, is similar to that from private households. Waste from EEE likely to be used by both private households and users other than private households shall in any event be considered to be WEEE from private households.

Please refer to The Waste and Electronic Equipment Regulations 2013 for further information.

FAQ’s

The following are our frequently asked questions. If you have a question that we have not answered below, please email the team.

GENERAL FAQS

Who are Recolight?

Recolight is a producer compliance scheme specialising in the recycling of all WEEE lighting in accordance with the WEEE Regulations.

Recolight was established in 2005 by the UK lamp producers who account for a significant share of the UK market.

Its members are producers and importers of EEE who put new lamps on the market for the first time in the UK, and are therefore obliged to comply with the WEEE Regulations.

Recolight offers specialist recycling services for all WEEE lighting, advice and support to help all parties in the supply chain recycle their lamps as simply and efficiently as possible Recolight is unique in the WEEE lamp industry, in undertaking recycling in excess of its legal obligations. This reflects the organisations, and its members’ genuine commitment to maximising the recycling of lamps.

As a not for profit organisation, all funds are used to promote and maximise recycling, and not used to pay dividends to stake holders.

Scheme approval number issued by the Environment Agency is WEE/MP3838PR/SCH.

What are the WEEE Regulations?

The Waste Electrical and Electronic Equipment (WEEE) Regulations (S.I. 2006:3289) and the WEEE (Amendment) Regulations 2007 (S.I. 3454) stem from an EU Directive of the same name and that Directive has now been rolled out across all EU countries. It came into full legal effect in the UK in July 2007

The WEEE Regulations ensure electrical and electronic equipment (EEE) is recycled in a sustainable way when it reaches end of life. The legislation is in place to reduce the impact electrical waste has on the environment by encouraging its reuse or recycling, and obliges manufacturers to fund the collection and recycling of their products when they reach end of life.

The regulations require all producers to join a compliance scheme which manages the process on their behalf, and schemes such as Recolight – which works on behalf of the lighting industry – provide these services free of charge to the end user. Under the Regulations the producer funds the collection, recycling and any environmentally friendly disposal. But it is the end user that has ultimate responsibility for making sure the product is recycled when it reaches end of life.

Who do the WEEE Regulations affect?

The WEEE Regulations affect everybody in one way or another but the primary groups affected are:

  • Producers, who become responsible for financing the end-of-life treatment of their products
  • Distributors, who become responsible in some cases for taking-back end-of-life products when new products are purchased and for providing information to users about the need for recycling and facilities for the disposal of end-of-life products.

A producer is the party which first puts Electrical or Electronic Equipment (EEE) onto the UK market, whether they are manufacturers of EEE, private brand distributors or importers. The primary responsibility is to finance the environmentally sound disposal of their products at end-of-life.
A producer is any person who:

  • Manufactures and sells electrical and electronic equipment under their own brand
  • Resells, under their own brand, equipment produced by another supplier
  • Imports electrical and electronic equipment on a professional basis into an EU Member State

Producers of Electrical and Electronic Equipment (EEE) as listed in Schedule 2 of the UK WEEE Regulations are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users. There are some exemptions and limits to this that can be found in the detail in the Regulations. For Example: non-Household WEEE where there is no like-for-like replacement.
Producers must join a Compliance scheme (or provide their own Environment Agency approved scheme) which will meet this responsibility by managing and paying for the recycling and recovery of their share of this WEEE and report on what they have done to the appropriate Government authority. Full details may be found in the BIS Guidelines.

Which lamps are covered by the WEEE Regulations?

Category 13 products in scope of WEEE

lighting in scope of WEEE regualtionsregulations

Gas discharge lamps:

  • Straight fluorescent tubes
  • Circular fluorescent tubes
  • Compact fluorescent lamps
  • High Intensity Discharge lamps
    • High pressure sodium HPS or SON
    • Low pressure sodium SOX lamps (street lighting)
    • Metal halide
    • Ceramic metal halide
    • Mercury
    • Xenon
    • Induction

Most of these lamp types are used in both household and non-household applications. All gas discharge lamps  are identified under the Hazardous Waste Regulations as hazardous waste.

Collection of waste xenon lamps

Collection of waste sodium lamps

LEDs

  • LED retrofit lamps
  • OLED retrofit lamps
  • User replaceable LED modules – Zhaga modules

Category 5 products in scope of WEEE regulations

  • Traditional luminaires
  • LED luminaires
  • LED street lighting

A Luminaire is a complete lighting unit consisting of a lamp or lamps and also the parts which help to position, protect or connect the lamps.

Our Luminaire collection and recycling service is provided for our members obligated waste.

Not in scope of the WEEE regulations

  • GLS
  • Halogen lamps
  • Household luminaires

are not in scope of the WEEE regulations, and not collected by Recolight.

Who is responsible for enforcing the WEEE Regulations?

The Environment Agency for England and Wales,

Scottish Environment Protection Agency

and Northern Ireland Environment Agency

are responsible for ensuring that all eligible producers and suppliers register with a compliance scheme.

The compliance scheme is then responsible for the producers’ obligations and for getting data from its members on EEE put onto the market and for reporting on WEEE collected and recycled.

In order for us to demonstrate to the enforcement agencies that our data is correct we audit all our members. This is on a random basis and no more onerous than necessary to achieve the objective.

LIGHTING PRODUCERS FAQ

How does Recolight’s compliance scheme work?

Recolight takes on the legal responsibility of its producer members to comply with the WEEE Regulations through a binding agreement.

Recolight is a not-for-profit company and passes on, to its members, the costs and financing it incurs each year in carrying out the various tasks of its business plan on behalf of the members.

For example:

  • Recycling services.
  • Investment in marketing to raise awareness of the need to recycle and the Recolight brand.
  • Administration costs and ensuring a viable financial base for the compliance scheme.

Our cost recovery method is to calculate a flat charge per lamp type which is then applied equally to all members.

This ensures the process is equitable to all and kept simple and cost effective.

 

A producer’s obligation under the WEEE Regulations

The WEEE Regulations state that:

“Producers of electrical and electronic equipment (EEE) are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users.”

 

If you put a product in scope of the WEEE regulations onto the UK market by any of the following:

  • Manufacture and sell electrical and electronic equipment under their own brand.
  • Resell, under their own brand, equipment produced by other suppliers.
  • Import electrical and electronic equipment on a professional basis into an EU Member State. This includes imports into the UK from other EU member states

You must join a compliance scheme which will meet your WEEE responsibility for you by financing the safe disposal of all products at end-of life.

Recolight, who will manage this responsibility on your behalf.

It is your obligation as a producer to:

  • Mark all EEE with the wheelie bin symbol
  • Declare WEEE number to distributors
  • Provide recycling information of all EEE
  • Sign an annual declaration of compliance

A full list of your responsibilities can be found on the Environment Agency website.

Administration and reporting

  • There is an initial process of registering on the Recolight Black Box secure website and returning signed copies of the Scheme Rules Agreement.
  • The monthly data update will only take a few minutes each month via the Black Box.
  • Thereafter Recolight will take care of your legal obligations on your behalf and provide information on an as-required basis to support your business.

All schemes must report data in a standard format to the enforcement agencies and we have designed our own formats in the same way as a matter of efficiency.

To demonstrate to the enforcement agencies that our data is correct we audit our members. This is done on a random basis and no more onerous than necessary to achieve the objective.

Black Box timeline of events

Monthly

Each month you are required to advise Recolight of your placed on market units and their aggregated weight. An accurate declaration must be made between the first and fifteenth day of each month, following the month end.

Environment Agency rules for declaring are:

  • B2B All goods placed on market within any calendar year must be declared no later than 15 January of the year following.
  • B2C All goods placed on market must be declared quarterly.
  • If your company is declaring B2C, then regardless of unit quantity, you must declare these figures quarterly.

Annual confirmations

An annual confirmation is a confirmation of the information your company has supplied to us throughout the previous year, summarised on a single page document.

You carry out this process after the 16 January each year and have up until the 15 February to complete. It takes just a few minutes.

This is an EA requirement.

Annual Declaration of Compliance

The annual declaration process starts around the first week of September each year, and you have until 16 November to complete. All members are emailed a document with questions; this must be printed, answered, signed by a director or senior manager and then scanned or posted to Recolight.

Who is responsible for enforcing the WEEE Regulations?

The Environment Agency for England and Wales, Scottish Environment Protection Agency and Northern Ireland Environment Agency are responsible for ensuring that all eligible producers and suppliers register with a compliance scheme.

The compliance scheme is then responsible for the producers’ obligations and for getting data from its members on EEE put onto the market and for reporting on WEEE collected and recycled.

In order for us to demonstrate to the enforcement agencies that our data is correct we audit our members. This is on a random basis and no more onerous than necessary to achieve the objective.

Do Recolight enforce Regulation 9.2?

Regulation 9(2) was a clause in the WEEE regulations that allowed producers to pass all their financing obligations for recycling on to their B2B customers – but only if there is a clear agreement between producer and the final business end user.

Given the complex, multi-level distribution networks that exist in our industry, we were convinced that this didn’t work for lamps. By passing the liability onto your customer

  • you are giving them a problem – how to recycle,
  • rather than a solution – recycling available through Recolight.

Consequently, the Recolight membership agreement does not allow producers to use regulation 9(2).

The new WEEE regulations clarify 9(2)

12(2) sates:

(2) Nothing in paragraph (1) will prevent a producer from concluding an agreement with users other than private households to make alternative arrangements between themselves to finance the costs of the collection, treatment, recovery and environmentally sound disposal of WEEE.

The change is to make it clear that the agreement must now be between B2B end users and producers.  So the old reg 9(2) approach can now only work where there is a direct contractual relationship between the Producer and the B2B End User.  It therefore cannot apply to sales through intermediaries (eg Wholesalers or contractors).

How does the refund request system work?

Businesses buying lamps from Recolight members which are then exported outside of the UK are able to obtain a partial refund of the purchase price.

As a compliance scheme, Recolight is unique in organising refunds from its members for exports of EEE.

Recolight has no involvement in the price paid for the lamps (and how much, if any, of Recolight’s WEEE costs to its member are included in that purchase price) – this is entirely between the producer and the buyer.  However, Recolight is able to administer a refund mechanism on behalf of the relevant Recolight member, unless that Recolight member has opted out.

Please note that exported lamps will usually need to be re-declared as EEE in the country into which they are sold. This is because they will contribute to the waste stream in that country.  It is the responsibility of the new importer in that country to declare them as EEE.

How to apply for a refund request

Recolight’s web-based system allows the members’ customers to apply for an export refund.  You will be asked to provide appropriate evidence that the products have been sold and exported.  Where necessary, Recolight will separately obtain confirmation of the WEEE costs included in the purchase price from the Recolight member.

Refunds can be requested through our Black Box system.

If you need help completing your refund request, or are an existing refund requester, and need a new copy of the support manual,

please email members@recolight.co.uk

What is the distributor takeback scheme?

The Distributor Takeback Scheme (DTS) enables distributors to discharge any household take-back obligations that they might have rather than provide in-store take-back facilities themselves. This mainly involves directing customers to the nearest local authority recycling centre, which membership funds of the DTS contribute to.

Wherever possible Recolight would encourage distributors to provide the most simple solution for customers to recycle their lamps to help encourage more recycling and reduce the amount of harmful waste going to landfill.

Providing in-store take-back avoids the temptation for a household user to put waste lamps in with the general household waste if the journey to a local authority site is difficult or inconvenient.

Recolight have 800 Bulbstore containers across the UK, working in partnership with retailers and Local Authorities, helping to make it easier for consumers to recycle.

BUSINESS END-USERS FAQS

What is the risk of a broken fluorescent lamp?

Scientists at the Health Protection Agency have reviewed the potential health effects of mercury exposure from broken fluorescent lamp. They found the exposure is likely to be very small – and much lower than from other broken mercury-containing products such as some types of thermometer and barometers.

Professor Virginia Murray, Consultant Medical Toxicologist, said: “Compact fluorescent lamps contain a tiny amount of mercury – roughly enough to cover the tip of a ball point pen.  A small proportion of this could be released into a room if the bulb is broken, but this does not pose a health risk to anyone immediately exposed.

“As a precautionary measure, the Health Protection Agency advise that the room should be ventilated and the bulb cleaned up and disposed of properly.”

How to clean up a broken lamp ?

The amount of mercury in fluorescent lamp is between 1.2 to 4 milligrams even though the amount is very small, you should still follow the following guidelines given, by the Health Protection agency, to safely remove the broken bulb.

Preparation

Vacate the room and keep children and pets out of the affected area. Shut off central air conditioning system, if you have one.

Ventilate the room by opening the windows for at least 15 minutes before clean up.

Do not use a vacuum cleaner, but clean up using rubber gloves and aim to avoid creating and inhaling airborne dust as much as possible.

Cleaning up

On hard surfaces sweep up all particles and glass fragments with stiff cardboard and place everything, including the cardboard, in a plastic bag. Wipe the area with a damp cloth and then add that to the bag. Household cleaning products should be avoided during clean up despite the very small amount of mercury involved.

On soft furnishings and carpets, do not use a damp cloth, just sticky tape to pick up small residual CFL pieces or powder from soft furnishings and then add that to the bag.

Disposing of the bulb

The plastic bag should be reasonably sturdy and needs to be sealed, but it does not need to be air tight. The sealed plastic bag should be double-bagged to minimise cuts from broken glass.

The bag with all broken pieces and cleaning items should then be taken to your local council recycling centre, where you will find a special section for WEEE.

What reporting process are in place for waste lamps

Procedures to record the movement and collection of hazardous WEEE vary across the four UK environment agencies:

Environment Agency for England

Scottish Environment Protection Agency

Northern Ireland Environment Agency

Natural Resources Wales

Tracking waste lamps

Consignment notes (waste transfer notes) are issued in multiple copies, including sheets for the end user, (producer of the waste), the transporter and the recycling plant. These are free in England and Wales, but small charges apply in Scotland and Northern Ireland.

Storage and Movement of waste lamps

Licenses, permits and exemptions are in place for the storage and movement on lamps on and between your sites.

Again, these vary across the UK. For some Environment Agencies there is no cost for you to apply for a license to store your lamps and no charge for a waste carrier license.

The Paper Work information outlines the processes along with any costs associated.

The cost of recycling

Recolight offer a free container, collection and recycling for those collection over 1000 lamps within three months. We have other free recycling services for those who collect less than 1000 lamps – and also for on off collections. We can provide this as a free service as we are funded by our members, the lighting industry.

Our service level agreement outlines additional costs you may incur for a

  • failed collection,
  • low weight,
  • excess wait time,
  • contamination in container.

These charges are passed onto us and therefore our passed onto those collection points who fail to meet our terms of service.

The four UK Environment Agencies have process in place to monitor the movement, storage and collection of waste lamps. Costs for licenses, permits and consignment notes vary for all four, and some are free. Refer to our section: The Paper Work where you can find information about additional costs.

USEFUL LINKS

EucoLight-

EucoLight

The creation of EucoLight is an important milestone for WEEE compliance schemes in Europe that focus on lamps and lighting who will now have a face and voice in Brussels. EucoLight is helping to strengthen its members’ activities and services around Europe, helping them to:

   Promote a better lighting products recycling service, aiming
to an efficient circular economy.

As a founding member, Nigel Harvey, Recolight CEO, is also a member of the EucoLight board.

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Lighting Europe
Lighting Europe is an industry association representing leading European lighting manufacturers and national lighting associations. They are committed to innovation, sustainability, quality and leadership. They contribute to shape policy, establish industry standards & guidelines and are dedicated to promoting efficient lighting practices for the benefit of the global environment, human comfort, and the health and safety of consumers.

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The Lighting Industry Association‘s mission is to strengthen the industry and promote the benefits of good quality lighting by representing all aspects of UK, EU and international legislation and standards at the highest level whilst protecting the interests of both the public and members

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