The Department of Business, Innovation and Skills (BIS) has issued a consultation document to amend existing statutory guidance in response to the European Commission’s FAQ document on the Recast Directive. The UK’s traditional position has been based upon nature and quantity and has left it for the Producer to decide when placing EEE onto the market. This is in contrast to the EC position which now relates to the nature of the product (e.g. an item used both in the home and in a business environment would be viewed as B2C).
David Burton, Managing Director of Strateco and advisor to B2B Compliance and PV CYCLE UK commented “We need to avoid additional costs being inadvertently placed upon the B2B sector by having a market share of waste consumer products being allocated to Producers whose end users are clearly in the B2B sector. This is particularly relevant for the photovoltaic sector where the Department of Energy and Climate Change’s (DECC) own statistics on the Feed In Tariff shows 35% of PV installations (by output and therefore weight) going into non-household installations.”