6 Replies Latest reply on Jun 24, 2011 3:58 AM by VictoriaJones

    WEEE recast update

    VictoriaJones

      The latest predictions for the release of the final WEEE recast Directive from the European Council suggest that it will enter into force this autumn. Findings from a recent BIS meeting suggest that the 10 category scope will remain a ‘closed scope’ for at least six years, although this will be subject to review within three years by the commission. Exemptions will also remain the same (so military equipment and equipment designed and installed as part of another type of equipment will still be exempt).

       

       


      Proposed collection targets for the recast remain as a staged approach with a 45% target starting four years after the recast comes into effect. This would then rise to 65% a further four years later. To put this into context, in 2010 the UK achieved a 38.4% collection rate. The actual collection targets will be calculated as a % of the average weight of EEE placed on the market by that country in the previous three years. Recycling, reuse and recovery targets for categories 1 -7, 9 and 10 are proposed to increase by 5% three years after entry into force, but medical equipment (category 8) will be subject to much higher 75% recovery and 55% recycling and reuse targets.


      What are your thoughts on the proposals? How will it affect your business – is it just further burden on industry or necessary progress? Let us know.

       

       

       

       

       

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        • Re: WEEE recast update
          michaelkellett

          Like so many EU directives this one disproportionally affects small businesses by imposing cost and bureaucracy on them for very little gain to the environment.  The net effect on the envirionment will be negative for most small businesses. There should be an exemption from WEEE registration for outputs of less than 1000kg per year. The absurd complexity and generally perceived silliness of the whole WEEE process may explain why so many businesses just ignore it completely.

            • Re: WEEE recast update
              TomW

              The objectives of the WEEE Directive are “to preserve, protect and improve the quality of the environment, protect human health and utilise natural resources prudently and rationally… environmental damage should as a priority be rectified at source and that the polluter should pay.” The argument is that every business has a responsibility to ensure safe creation and disposal of their products, no matter how big or small the quantity, as the effect is global.

              However, it can also be argued that the complexity of the WEEE Directive poses a greater burden to smaller businesses.  Categorisation and reporting are time consuming processes requiring skills and resources not always available to the SME.  Larger businesses have the ability to absorb the cost incrementally through increasing costs across products and investing in better disposal practices.

              So, do you think a simplified, scaled approach to legislation would be the solution?  Or should all WEEE be subject to the same rules, no matter the size of the producer?

                • Re: WEEE recast update
                  michaelkellett

                  Hello Tom, nice to see you here.

                  The idea that every business, regardless of size, should be treated the same way for WEEE makes no more sense than, for example, requiring every business, regardless of size, to have its own firefighting service. The sensible thing to do is for some businesses at special risk to do so but most use the national service paid for out of taxation (local and national). Disposal of waste is no different, it is much more efficient that small amounts go through the public system while large amounts may require alternative arrangements.

                  My suggestion is that there should be no requirement for registration for annual amounts below 1000kg and no requirement for special arrangments below 10,000kg pa. I think that in many cases it would be far better for the producer to make a contribution to the cost of the public waste disposal system for even large amounts of material because the reality is that most waste will end up there anyway.

                    • Re: WEEE recast update
                      VictoriaJones

                      Hi Michael,

                       

                      Following your responses to our recent post, we contacted BIS (UK department for Business Innovation and Skills) in order to get an official viewpoint on the issue.

                       

                      BIS is fully aware that there is no room in the current scope to exempt small businesses (or businesses that only place small amounts of EEE on the market) and have been pushing during the course of the recast to get a 'de minimis' provision included as a Member State option. Unfortunately during the discussions around the first reading of the Commission's proposals, there was not enough support from other Member States to make it successful.

                       

                      However, BIS is looking for opportunities to raise the issue again during the second reading of the proposals. This is likely to take place under the Polish Presidency of the EU in the latter part of 2011.

                        • Re: WEEE recast update
                          michaelkellett

                          Hello and thank you for the update.

                           

                          I'm pleased to hear that BIS is on the case but less happy that other EU members are not interested - do we know why not or what their objections are ?

                            • Re: WEEE recast update
                              VictoriaJones

                              Hi Michael,

                               

                              Gary Nevison (Head of Legislation and Compliance at Farnell) recently attended a BIS regulatory update on RoHS and WEEE recasts. We can confirm that BIS will be supporting the addition of a 'de minimis' provision at the second reading, although they have also reiterated that there is very little support from other Member States, although unfortunately further details on specific states and reasons for the opposition were not given.