The Department of Business Innovation and Skills (BIS) has confirmed that it has received three bids to operate the Compliance Fee system – introduced under the revised WEEE Regulations as an alternative form of compliance. Bids have been received from a consortium of five Producer Compliance Schemes, the Environment Exchange and the Joint Trade Associations (JTA). The JTA proposals include:
- A clear and simple-to-operate fee calculation methodology, based upon rigorous analysis from one of the UK’s leading economics consultancy groups.
- The appointment of a top ten UK accountancy firm to be the independent system administrator; responsible for the receipt and distribution of funds and the handling of all confidential information.
- A streamlined and uncomplicated process for Local Authorities to apply for funds, based on the requests and suggestions they have made to the JTA.
The JTA, which represents nine major trade associations in the electrical sector (AMDEA, BEAMA, BTHA, EEF, GAMBICA, LIA, PETMA SEAMA and techUK) responded after BIS invited interested parties to propose a compliance fee mechanism in accordance with the 2013 WEEE regulations. The compliance fee provides an alternative means of compliance if a Producer Compliance Scheme (PCS) does not obtain sufficient evidence to satisfy its producers’ collection target obligations.
BIS intend to consult on the proposals later in October and, while not mandatory, may approve a methodology for the calculation of a compliance fee and the appointment of a third party to oversee the administration of that fee. The Government has indicated that the latest a final decision would be announced is mid-February 2015.
Chairman of the JTA and Technical Manager at the Association of Manufacturers of Domestic Appliances, Richard Hughes said, “The compliance fee is an important element of the new WEEE system. It acts as a safety valve, ensuring that where a PCS has not fully met its target through collections during the compliance period, it has a legitimate alternative route to compliance. The methodology proposed by the JTA increases the compliance fee the further a PCS is from its target. This is designed to ensure collection of WEEE is encouraged as the main route to compliance and creates a fair, balanced market.”
David Burton, Managing Director of Strateco, commented on the impact of the potential introduction of the Compliance Fee, “The combination of the introduction of fixed collection targets, and the potential option of PCSs to use the Compliance Fee as an alternative form of compliance, have already had a significant impact in that the balance of power is shifting between those PCSs that hold surplus tonnage and those that are short of evidence. In the past this imbalance risked exploitation of those ‘short’ PCSs that did not have access to tonnage – it will be interesting to see whether the ‘surplus’ PCSs will surrender their WEEE contracts – mainly held with local authorities – or risk bearing the costs.”
The European Commission has formally adopted proposals for the future of waste and recycling targets within Europe, as part of measures towards achieving a circular economy.
A key proposal is for an increased target for Member States to recycle or reuse 70% of municipal waste by 2030, an increase on the current 50% by 2020 target.
The Commission is also proposing a ban on sending recyclable materials such as plastics, paper, metals, glass and biodegradable waste to landfill by 2025, as well as phasing out landfilling of waste by 2030. Having been adopted by the European Commission on 2nd July, the proposals will pass to the European Council of Ministers and the European Parliament for consideration by politicians. Other proposals that have been put forward by the Commission include an 80% by 2030 reuse and recycling target for packaging waste, which includes material specific targets that will gradually increase from 2020. These will see ambitions set for 90% of paper and cardboard to be recovered by the end of 2025, 60% of plastic packaging, 80% for wood and 90% for ferrous metal, aluminium and glass by the end of 2030. Measures to encourage a 30% reduction in the amount of food waste generated by Member States by 2025 are also set to be considered, while the Commission is proposing to put in place an early warning system to anticipate difficulties of Member States to achieve targets. The Commission is also keen to encourage greater sharing of best practice between Member States, including better use of economic instruments to encourage recycling include pay-as-you-throw schemes, incentives, as well as taxes on landfill and incineration.
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.”
Between 4-5 million tonnes per year of light iron is recycled in the UK annually, which contains a certain amount of WEEE and, while it is correctly processed and recycled, it is not reported or counted as WEEE. This is known as non-obligated WEEE.
Large domestic appliances (LDA) form a proportion of this non-obligated WEEE and the Waste and Resource Action Programme (WRAP) embarked upon collection trials in late 2013/early 2014, which estimated LDA to be around 11% of the light iron stream. This reports constitutes a major finding as it is possible that this non-obligated LDA (and any other identified WEEE streams) could potentially count towards the UK’s WEEE collection targets under the ‘substantiated evidence’ approach referenced in the Recast WEEE Directive. David Burton, Managing Director of Strateco commented, “I have been a strong advocate of the ‘substantiated estimates’ approach being used to assist the UK to meet the Directive targets – it is clear from the consistent 5% collection rate recorded under the WEEE regulations for non-household WEEE that 95% of it is going elsewhere outside of the WEEE system and it just needs to be identified and accounted for – preferably using protocols rather than requiring details reporting mechanisms”.
A summary report from WRAP sets out the methodology for data collection and interim findings and a full report, with further data, confirms that 10.87% (+/- 2.4%) of the light iron processed is LDA. More details from http://www.wrap.org.uk/node/18591
After lengthy consultation the new WEEE Regulations, resulting from the transposition of the Recast WEEE Directive, have now been laid before Parliament and come into effect on 1st January 2014
One of the key issues is the introduction of mandatory collection targets for compliance schemes and mechanisms to prevent the ‘trading’ of evidence of household WEEE collections between schemes which producers claim was leading to a significant increase in the cost of compliance. Scheme that over collect will be required to finance the excess (or retain the income – depending upon the net value or cost of the recycled WEEE) , and under-collecting schemes will have to pay a ‘compliance fee’ per tonne of WEEE it has been unable to collect or obtain WEEE evidence from other schemes.
The regulations can be downloaded from here
Following the acquisition of Strateco by Budget Pack Ltd the business will be moving on Friday 13th December to Bristol.
Managing Director David Burton stated “ We look forward to working alongside Budget Pack and in reinforcing the skills that both organisations bring into the relationship”. James Potten, Managing Director of Budget Pack, announced “As the Producer Responsibility marketplace changes we look forward to building up on the strengths within each company and developing further services to our client base”.
The new address will go on the Contact Us page w/c 9th December.
Bristol-based environmental compliance and consultancy business, Budget Pack Ltd, has acquired Oswestry-based Strateco Ltd, a company specialising in WEEE compliance and environmental consultancy.
Following a long-standing and positive relationship between both companies, Budget Pack Environmental has agreed a deal to acquire Strateco Ltd as a subsidiary company, which will continue to provide unbroken services to its key clients – most notably ‘B2B Compliance’.
The Chairman of Budget Pack Environmental, Steve Clark, commented, “We are delighted that Strateco is now part of the Budget Pack Group. We have identified great synergies and its acquisition introduces greater depth to our management team which will assist us in our growth plans.”
David Burton, Managing Director of Strateco responded, “Both companies share a common ethos and values and working within the Budget Pack Group provides longer term security for our clients as the compliance market goes through considerable change.”
Further information about the acquisition, and the way in which the companies will work together going forward, will be released in due course.
The Department of Business, Innovation and Skills has recently published its second round of consultation on the transposition of the Recast WEEE Directive and changes to address market dysfunctions for household EEE.
The key proposed changes include:
- Inclusion of photovoltaic panels within a new category 14
- LED lamp Producers to bear the costs of collection of hazardous WEEE lamps
- Producer Compliance Schemes (PCSs) to have an option of paying a Compliance Fee rather than for evidence of collection/treatment
- Introduction of collection targets
- Use of ‘substantiated estimates’ to contribute towards meeting the targets
- Introduction of a de minimis
- Move to open scope from 2018
The final regulations are expected to be published in December and will come into force on 1st January 2014
Since the release of the Environment Agency guidance stating that pentane fridges must be treated as hazardous waste, a number of warnings have been given by councils and recyclers on the rises of fridge fly-tipping and the shortage of available fridge recycling plants. Recent fly-tipping has especially been seen by councils in the West Midlands and Derbyshire area.
The ruling, published in February, relates to the pentane blowing agent used in the insulation foam as an alternative to CFCs. The Environment Agency (EA) has stated that in order to prevent the risk of fire at fridge storage and treatment sites, pentane fridges can only be treated at sites permitted to process hazardous waste. As a result, metal recyclers are no longer able to shred pentane fridges, instead having to send them to dedicated fridge reprocessing facilities to be degassed. As such, many are claiming that there is insufficient capacity currently in operation to deal with the tonnage of fridges being produced and, consequently, there has been an increase in the gate fees being charged by fridge recyclers.
According to the EA, “since we issued our guidance there has been a significant increase in the number of fridges being processed through dedicated fridge processing plants, which we see as a positive move. Our recent enquiries indicate that there are fridge processing plants with sufficient capacity so there is no firm evidence that a lack of capacity is causing fridges to be fly-tipped” – there has been no comment from the EA on gate fee charges as this is deemed to be outside of their regulatory responsibilities.
The full article regarding this issue can be found on the Lets Recycle page by clicking here
The national electronic duty of care system – Edoc, a replacement for the current duty of care paper trail, is due to be launched in January 2014. The RWM exhibition in Birmingham gave a good platform to preview this programme to a number of waste management companies, local authority delegates and others.
Edoc is being developed by the Environment Agency, in partnership with CIWM (the Chartered Institution of Waste Management), and is co-financed by the EU LIFE+ programme. It looks to offer an alternative to the existing paper-based waste transfer note system by creating an online document management system that can accessed via a web portal.
It is designed to reduce the administrative costs to businesses that produce a waste transfer note (WTN) for each movement of waste. Currently over 25 million paper-based WTNs are produced each year and need to be stored for at least 2 years. The Edoc system also aims to make it easier for businesses to track their waste and record data by having an online archive whereby WTNs can be easily retrieved for auditing purposes, and by providing email notifications for any actions that are required to complete a WTN.
CIWM chief executive Steve Lee said: “We support the production of Edoc which could replace the need for costly business waste surveys, saving government around £1 million per annum”.
There are, however, some concerns over the fact that paper hazardous waste consignment notes and cross border documents will still need to be produced. When questioned whether a timescale had been considered to include hazardous and cross border waste documentation within the Edoc system, the organisers said that “they would monitor the initial success before considering if it should be rolled out across other areas.”