Product category: Compliance Engineering
News Release from: Valpak | Subject: WEEE compliance
Edited by the Electronicstalk Editorial Team on 22 November 2006
Are producers ready
for WEEE compliance?
If the implementation of the WEEE Directive achieves its laudable aims it will be well worth the wait, says by Mike Sadler, Head of WEEE Services at Valpak
After a number of delays, the UK Government has declared July 2007 as the likely start date for the implementation of the Regulations developed in response to the European Union's Waste Electrical and Electronic Equipment (WEEE) Directive. These regulations will place the main legislative burden for recycling the estimated one million tonnes of waste electrical equipment produced in the UK every year firmly on the shoulders of producers and importers of WEEE.
This article was originally published on Electronicstalk on 22 November 2006 at 8.00am (UK)
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In addition, retailers will be required to provide in-store take-back services, or contribute towards a network for the return of waste electrical equipment.
Though that date next summer - dubbed by some WEEE Day - may seem a way off, it would be a mistake for producers to push it to the back of their minds.
They should take the opportunity presented by this interim period to ensure they are fully prepared for compliance.
According to the most recently proposed timetable produced by the Department of Trade and Industry (DTI), the arrangements for implementing the WEEE Directive could reach the statute books by 1st January 2007, with a phased implementation taking place between April and July 2007.
Since 2003, when the EU's Directive was first published, the Government's proposals for implementing the WEEE Regulations have undergone an extensive and protracted period of consultation and review.
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The DTI, the Government agency responsible for transposing the WEEE Directive into national law, has been consulting with interested stakeholders, including representatives of the producers, retailers, the waste management industry, Local Authorities and SMEs.
Valpak is among the organisations who have been actively involved in discussions with Government policymakers, with the aim of ensuring that the principles of the WEEE Directive are translated into a system that will be as practical and workable as possible.
It has been estimated that the WEEE Directive will affect from 8000 to 15,000 producers and importers of electrical and electronic equipment (EEE) in the UK.
This will include a broad range of companies, ranging from large organisations like Tesco, J Sainsbury and Sony to small, specialist manufacturers.
Under the proposed legislation, producers will be responsible for the collection and treatment of household and nonhousehold WEEE from designated collection facilities (DCFs).
These facilities will be part of a national network.
In this context, the term 'producers' includes UK-based Original Equipment Manufacturers (OEMs), retailers who sell own-branded EEE and organisations who import EEE from overseas manufacturers.
Therefore, if you are a producer who manufactures and sells under your own brand, a brand owner of equipment manufactured by others, or an importer of EEE you will face a number of new requirements.
You will be required to: register with an appropriate environment agency; provide the agency with full data on the quantity and weight of EEE they put on the market each year; mark all EEE with the crossed out wheelie bin symbol, to show that the equipment should not be disposed of in the normal waste stream; and fund the transportation, recovery and recycling of collected WEEE to required standards.
Having registered for WEEE compliance and provided the required data, each producer's market share will be calculated.
Producer compliance schemes - or individually registered producers should they choose to go it alone - will then have to collect WEEE deposited at DCFs in proportion to their market share.
The Directive encourages WEEE to be collected separately, to promote reuse, recovery and recycling.
The producer sector is currently liaising with Local Authority representatives on a Code of Practice that will govern the relationship between producers and the Local Authorities, since it is expected that most DCFs will be provided at Local Authority Civic Amenity (CA) sites.
Valpak is working with Local Authorities and their representative groups to develop an offer that will ensure an 'adequate network' of collection facilities.
This will cover a similar geographical pattern to the existing CA sites and will comprise up to 1070 sites in total, giving reasonable public access throughout the country for people who wish to deposit WEEE.
WEEE will be collected at these DCFs, wherever possible, in five categories: large household items containing ozone-depleting substances; large household items not containing ozone-depleting substances; televisions and monitors; fluorescent tubes; and all other WEEE.
Though they can choose to register individually, the WEEE regulations give producers the option of meeting their obligations by joining a producer compliance scheme.
The compliance scheme will then take on the legal obligations of its members.
Obligated companies will naturally want to achieve full legal compliance at the lowest possible cost, with minimum hassle and effort.
Joining an approved compliance scheme can provide the most cost-effective route to fulfilling their obligations, since such schemes will be able to make use of economies of scale inherent in a collective system.
Being part of a producer compliance scheme has other advantages too.
Companies who join a scheme can hand over their legal responsibility and be sure they are WEEE compliant, without having to worry about the small print of this complex legislation.
They will also benefit from operating under an overall WEEE recycling brand.
Valpak, for example, will be running a range of promotional and educational activities on behalf of its members, designed to increase public awareness and encourage participation.
Direct compliance by individual companies, in contrast, is likely to prove a more expensive choice, since costs such as transportation will be proportionately higher.
'Go it alone' producers will also face the onerous task of providing data to the appropriate agencies to demonstrate that targets have been met and the required WEEE weight collected, as well as estimating the financial implications to their business of the costs of WEEE.
Valpak, drawing on its experience as the leading provider of packaging compliance services, will be operating its own producer compliance scheme.
Until the legislation is implemented, Valpak - a not for profit organisation owned and run by its members - is offering member companies a free precompliance service.
The service, the largest in the UK, currently has more than 100 registered members, with names that include Smiths Group, Virgin Mobile and Lec Refrigeration Plc.
The precompliance service includes a range of solutions for both B2C and B2B producers.
These include a dedicated WEEE hotline, an online cost calculator that allows members to determine the potential cost of WEEE to their business, plus access to online and regional seminars and other information on the issues and the legislation.
The service also assures producer members of representation within key WEEE stakeholder groups.
The WEEE Directive was designed to address the huge problem presented by the landfilling of electrical and electronic waste throughout Europe.
Delays in the implementation of the Directive in the UK have been frustrating for everyone involved, not least producers.
However the postponements have afforded producers the leeway to prepare themselves and, through organisations like Valpak, have an input into the Government's decision-making processes, as well as allowing time for an adequate national DCF network to be established.
If the implementation of the WEEE Directive achieves its laudable aims - the delivery of important environmental objectives while safeguarding the competitiveness of UK producers - it will be well worth the wait.
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