Options for a new WEEE system
The government has indicated that it is considering at least three alternatives to the current system for household recycling.
We at Recolight warmly welcome the prospect of change. The current system is fundamentally flawed. It allows the holder of household waste to sell it, often at a significant profit, to those Producer Compliance Schemes (PCSs) that need the waste to comply with the WEEE regulations.
The WEEE regulations are “Producer Responsibility” legislation, meaning that Producers of electrical equipment have the responsibility for financing recycling when their equipment reaches end of life. But this responsibility should not be exploited for financial reward.
The four options for a new WEEE system
National Producer Compliance Scheme
All Producers of electrical equipment would be required to join a single national PCS. Whilst there is some merit in having a single scheme, the removal of any form of choice for Producers cannot be seen as positive.
Inevitably, different PCSs work in different ways, and the ability of a company to chose its PCS based upon a number of criteria makes sense. Recolight would not support such a move.
A National Allocation System
This system would match local authority collection sites with those PCSs which have the legal responsibility for funding the waste arising at those sites. This is clearly an attractive option. It removes the ability of intermediary companies to hold onto the waste, and then to sell it (or evidence that it has been recycled) to the PCSs which need it. It does mean that the “allocation system” would determine which PCS would be responsible for the collection of waste from a Local Authority rather than the authority concerned. However, this removal of choice would inevitably be a cause of concern for some Authorities.
To mitigate this concern, the Government’s proposal is that Local Authorities (or their subcontractors) could chose to handle the waste themselves, rather than using a PCS. This makes a lot of sense – much of WEEE waste collected has a value.
By allowing Local Authorities the option to collect the waste themselves, they can also retain the resulting revenues. That creates an incentive for them to increase collections – but they have the fallback option of using PCS funded recycling, if they want it. That considerably reduces the impact of an allocation system – and gives Local Authorities access to revenues.
However, it is unlikely that many authorities would chose to take responsibility for the collection of waste gas discharge lamps. Lamps have no net value at the end of life – instead there is considerable cost associated with their collection and recycling. That means Local Authorities could generally be expected to avail themselves of funded collections through PCSs.
Similar systems already operate successfully in a number of European countries, including Germany, Italy, and France. Most multinational companies are therefore familiar and comfortable with allocation systems.
As a PCS with a material obligation for the collection of household waste lamps, Recolight favours this option, recognizing that there would inevitably be some teething troubles during initial implementation.
A Targets and Compliance Fee System
The third option the Government is considering avoids the need for a Government backed allocation system. Instead, each PCS is given a mandatory target to collect a prescribed quantity of WEEE, dependent on the amount put on market by its members. If the PCS does not collect sufficient, then instead, it has the option to pay a compliance fee to the government or other central body. Any fees so collected would be used to support WEEE related projects.
Regardless of targets, any PCS would need to collect WEEE if requested by any Local Authority. This could therefore mean that some PCSs are required to collect much more WEEE than they need. To mitigate this risk, PCSs would be free to set up and join a “PCS Takeback Scheme”.
Such a scheme would have the effect of spreading the risk of collecting more WEEE than needed, amongst all PCSs that are members of the scheme. The PCS Takeback Scheme would still be likely to operate some form of allocation amongst its PCS members.
As with the second proposal, Local Authorities would be free to take responsibility for any WEEE they collect, but again, they are less likely to do so with waste streams such as lamps which currently represent a net cost.
Recolight also supports this option. However as it does not operate in any other country, getting the design of the system right is essential to avoid unintended consequences.
The Govenment launched a consultation period in May 2013 with a summary of the results published in August.