Strateco Chairman, David Burton, in his role as Project Director of B2B Compliance was asked once again to present a paper at the recent ERA Conference.
David outlined a number of the key challenges facing the B-to-B Producers unless the sector’s concerns were fully taken into account. One of the examples shown illustrated a potential 20 fold increase in Producers’ costs if they belonged to a minority tonnage category which was absorbed into one of the larger reduced categories and had to pay a market share contribution (as the recorded collection rates of the larger tonnage categories is far higher).
He was able, however, to present positive news in that BIS was taking the sector’s concerns on board and the role of ‘substantiated estimates’, as proposed by B2B Compliance, was increasingly being accepted.
February 28, 2013 I Rome, Italy
The third International Conference on Photovoltaic Module Recycling will be focused on the impact of the Recast WEEE Directive on PV module recycling. Speakers from across the world and PV recycling value chain will discuss technical developments and the benefits of recycling for the PV industry.
- Impact of recast WEEE Directive on collecting and recycling end-of-life PV modules: Challenges and solutions
- Recycling solutions for silicon and non-silicon based PV technology
- Technological developments in recycling end-of-life PV modules
- Comparison of existing take-back and recycling infrastructures in Europe: challenges and solutions
For further information go to http://www.pvcycle.org/3rd-international-conference-on-pv-module-recycling/
Strateco’s Managing Director, David Burton, gave a recent presentation to the WEEE Scheme Forum and representatives of the Environment Agency at the Forum’s latest meeting.
The presentation, already given to BIS officials, outlined some of the potential ramifications of forthcoming changes to the WEEE legislation and, in particular, the challenges relating to the new collection targets which come into force in 2016. The key issue is that the current collection rate of B2B WEEE, recorded within the WEEE system, is about 5% and, without taking into account that the majority of old products go down alternative ‘disposal’ routes (such as scrap, asset management etc.,) the forthcoming targets would be impossible for the B2B sector to reach. There is now an increasing recognition by the various stakeholders that an exercise needs to be conducted to identify and quantify these alternative routes.
Managing Director of Strateco, David Burton, gave a recent presentation to the WEEE Scheme Forum (which represents about 90% of the UK Producer Compliance Schemes’ obligations) and representatives of the Environment Agency on the issues facing the photovoltaic sector at the Forum’s latest meeting. The presentation, already given to BIS officials, outlined some of the potential ramifications of inclusion of PV panels within the scope of the new WEEE regulations. The Forum acknowledged the unusual nature of the sector in that many thousands of tonnes of product were now being placed on the market and yet little is coming off as waste and that which is, is not being disposed of through local authority collection points. Not only would the imposition of the forthcoming collection targets not be realistic for the sector but the tonnage placed on the market has a potential to impact upon the UK’s WEEE collection performance.
David did have the opportunity to explain that he has had a positive discussion with BIS officials relating to the transposition of the Recast Directive and he is confident that a workable solution will be found.
At yesterday’s ICER meeting the Environment Agency confirmed that their project to identify so-called ‘free riders’ is nearing completion.
The consultants employed within the project have explored, amongst other areas, companies registered under relevant SIC codes and those shown to be importing electrical or electronic products, in an effort to identify those companies who have avoided their obligations under the WEEE Regulations.
The consultant’s report is now in its draft stage and when it has been finally signed off will be circulated to stakeholders. Concern was expressed at the forum that when free riders have been reported to the EA there has been no subsequent feedback or evidence of action taken.
The Chairman of Strateco, David Burton, gave a presentation to BIS officials on 31st October related to the issues facing the photovoltaic (PV) sector under the forthcoming revised WEEE Regulations.
David described the meeting “It was a very positive and constructive meeting – with BIS officials being both aware of the challenges facing the sector and being in a listening mode. We discussed a number of options which could achieve a more equitable approach to that currently laid out in existing regulations where the sector would be penalised because of the market share calculation applied to products placed on the market. The fact that most PV panels will not appear as waste for another 25-30 years and, when they do, they will not go through the local authority collection infrastructure, justifies a ‘special case’ approach”.
Strateco is the consultancy appointed by PV CYCLE, the pan-European collection and recycling scheme supported by 90% of the photovoltaic manufacturers and importers active in Europe, which is now preparing for the mandatory inclusion of PV panels in forthcoming waste electrical and electronic equipment (WEEE) legislation throughout Europe.
At a meeting of the Environmental Regulatory Group of the GAMBICA Trade Association, David Burton, Chairman of Strateco, was invited to give a presentation on behalf of ‘B2B Compliance’, to the key team at BIS responsible for implementation of the new WEEE Regulations.
While the presentation titled ‘Potential Implication of the Recast Directive’ acknowledged the challenge to BIS related to consumer products, David Burton, stressed that resolving the B2C issues would not address potential major impacts on the B2B sector. Key issues were highlighted related to changes in the new regulations impacting upon the collection targets, scope and B2B products potentially being viewed as B2C. David Burton commented “I am impressed that BIS is taking on board our concerns and are open, and in listening mode to identify equitable solutions – I am confident that, with a pragmatic and understanding approach, we will find the best positioning for the B2B sector”.
Chairman of Strateco, David Burton, has raised the initial concerns of the photovoltaic sector at the recent WEEE Working Group meeting.
“There is clearly a special case for PV panels when they come within the scope of the new WEEE Regulations and we will be laying these out in the coming months. It’s important to recognise that the impact on all stakeholders could be substantial due to the PV sector placing significant tonnages of about 80-100,000 tonnes of product onto the UK market each year, but virtually no panels are appearing as waste due to their longevity.
The impact for overall Producers, who will need to collect as waste 45% of electrical and electronic equipment placed on the market from 2016, and pay a market share contribution, could be significant”. I look forward to laying out our case to the various stakeholders in the coming months prior to the formal consultation”.
The BIS-appointed WEEE Working Group held its first meeting on Monday 8th October as part of the preparation for consultation for the new WEEE Regulations. The key BIS objectives are:
- To achieve the Directive Collection Targets
- Address the costs of compliance
- Minimise bureaucracy
- Achieve the environmental objectives
- Ensure regulatory enforcement
David Burton, Chairman of Strateco, was particularly focused on ensuring that the potential unintended consequences for the B2B sector were not ignored “While we acknowledge that the majority of the debate is about achieving an equitable solution for the 1400 B2C producers we must not forget the 3500 B2B Producers who could, unless careful consideration is given, be hit with significant increases in costs. I am delighted that BIS is prepared to look at the so-called ‘substantiated estimates,’ allowed under the Directive, in recognition that much B2B products are not counted through the WEEE system at end of life – otherwise the impact on the B2B sector, which has a majority of SMEs could be devastating”.
PV CYCLE to lobby for sustainable and effective UK law
PV CYCLE, the pan-European collection and recycling scheme supported by 90% of the photovoltaic manufacturers and importers active in Europe, is now preparing for the mandatory inclusion of PV panels in forthcoming UK WEEE legislation and has appointed Strateco as its consultants.
PV CYCLE manages a European-wide dedicated collection and recycling network for PV modules and has already treated several thousand tonnes to date.
Managing Director of PV CYCLE, Jan Clyncke, stated “ As UK legislation currently stands, the PV sector producers would be unfairly financially penalised –through placing products on the market which will not become waste for 30 years or more, our sector will be paying excessive amounts for compliance with a law that was initially designed for electronic and electrical consumer and household waste”.
PV CYCLE has appointed the strategic environmental consultancy, Strateco, to assist them in seeking an optimum solution that ensures economic survival of PV module producers in Europe.
Strateco, which facility manages the Producer Compliance Scheme, B2B Compliance, and has advised a number of other schemes, welcomed the appointment. Chairman and Managing Director, David Burton, responded to Jan Clyncke’s points “ We need to ensure that the PV sector, which has already established a comprehensive and integrated infrastructure for PV panel recovery and recycling in the UK, can be permitted to meet its Producer obligations under forthcoming legislation without an excessive cost burden – as this would impact upon costs and therefore the effectiveness of the government Feed-In-Tariff initiative and dissuade development and investment in the PV sector”.
PV CYCLE believes that future legislation must include an ability for sectors to apply Individual Producer Responsibility, solutions which remain included within the European Directive. Jan Clyncke advised “At the end of March 2012, 244,934 installations were listed on the central Feed In Tariff register. The large majority of the installations – over 95% – are installations of less than 4kWp, with a possible average installation weight of almost 400 kilos, making PV panel installations effectively the heaviest domestic electronic products being placed onto the market. Legal frameworks need to take into consideration the nature of this product in order to be effective and sustainable. We look forward to working with Strateco and the UK government to achieve a positive outcome for the industry and its customers”.