Producers of Electronic & Electrical Equipment (EEE) will have new waste Regulations to follow

As from January 2014 producers of Electronic & Electrical Equipment are going to be effected by the introduction of the WEEE Regulations.

The Government concluded its latest Consultation with 256 responses, this October, of which 48% were from the Producers themselves. The government believes the responses received across all stakeholder groups were sufficiently representative to enable their views to have been properly considered during the consultation process.

What is a Producer Compliance Scheme (PCS)

A Producer Compliance Scheme helps its members to comply with the Waste Electrical and Electronic Equipment Regulations 2006. They offer expert advice, guidance and instructions on the WEEE Regulations and cost effective recycling solutions.

One of the key discussion points is clear in the Government consultation for producers to join an approved PCS (Producers Compliance Scheme) unless they fall below the de minimus threshold for EEE placed on the market when they will be required to register directly with a relevant environmental agency.

This continued stakeholder engagement or referred to as Extended Producer Responsibility of individual producer responsibility is one of the key changes in the new legislation.

These are important facts to know about the Producers Compliance Schemes to come:

  • All producers must join an approved PCS unless below the agree threshold for EEE
  • Registrations with the PCS needs to be reconfirmed annually. A proportion of the member state target will be allocated to each PCS annually on 31st March of the relevance compliance year.
  • Each PCS will be given a tonnage target by category of EEE
  • PCS's will be free to make any collection arrangements for household WEEE. Whilst a PCS may collect more or less than the obligation it has been given.
  • Producers should finance the treatment, recovery, and environmentally sound disposal of their EEE that they produce.
  • Evidence should not be transferred between schemes, but PCS may choose to contract with each other ahead of collections.
  • If a PCS collects to few there may be a COMPLIANCE Fee per tonne into a fund intended to support WEEE related projects or face appropriate sanctions for non-compliance.
  • A PCS must collect and finance the treatment and recovery of WEEE.

Producer Take Back Scheme

The consultation document and impact assessment proposed the possibility of a "Producer Take back Scheme" being established to mitigate the financial risk of the PCS being required to collect an amount of WEEE in excess of its collection take. There are concerns on the implementation time necessary for proper consideration to establishing the collection target and compliance fee methodology and the need to review any existing contractual arrangements.

Major producers have already demonstrated their support for PCS or Take Back schemes. When checking current policies on retails such as John Lewis or a producer such as Sony this is what they have to publish.

John Lewis They advertise they will remove packaging and if required for a further £9 will dispose of your old appliance.

They also state " that with their own-brand products that fall under WEEE regulations and as a producer of EEE they are a member of a Producer Compliance Schemes which take responsibility for recycling EEE products. "

Therefore under the new regulations should this service be for free?

Sony have a more general response to their core recycling schemes and state "In Europe, Sony are establishing systems for the collection and recycling waste electrical and electronic products with the aim of achieving extended producer responsibility while encouraging competition within the recycling market." also for commercial waste WEEE "Sony introduced the Business WEEE Collection Service (BWCS), a unique recycling service for professional customers"

"Its proactive engagement allows Sony to have increased control over the management of WEEE take-back.

RTS know that there are going to be significant changes in 2014 for the collection of WEEE for residential and Commercial businesses and hope to be a point of contact to assist in arranging the correct compliance for our customers.

Reference documents:

To view the full Governemnt Consultation you can see the PDF under this link: