WEEE Consultation & what to expect

The long awaited WEEE consultation is expected in the next few weeks. Informal discussions with stakeholder groups have taken place. That means we can be reasonably confident of some of the headline proposals on which they are likely to consult. The consultation will have two sections – firstly proposals for regulatory change, and secondly, a call for evidence in other areas.

Proposals for change to the WEEE System

• Moving the point of producer responsibility.
  In essence, providing householders with free of charge collection of WEEE. That may include strengthened obligations on distributors, in particular free collection of used appliances when delivering new appliances.
• Tackling the scourge of non-compliant product sold via online marketplaces.
  The likely solution would be to create a new class of producer. This would require online marketplaces to take on the financial obligations for collection and treatment of their overseas sellers. This would be consistent with the current packaging reforms.
• New category for vapes.
  Establishment of a new category for vapes to ensure the cost of collection and treatment of these products is correctly borne by vape producers.

Other changes and call for evidence

• Better embedding of circular economy principles in the regulations.
  That could include changes to drive a greater focus on reuse and repair, rather than recycling, and also measures to encourage better eco-design of new products.
• Measuring success of a reformed system.
  A review of how financial obligations on producers are set and the metrics that should in future be used to measure success of a reformed system.
• Reforming the business WEEE system
  Consideration for providing businesses with free of charge WEEE collection, subject to minimum quantities.

Challenges of the WEEE Reforms

For many of us in the industry, these changes to the WEEE system will be welcomed – but may also present some challenges.

Reuse over recycling

For too long, the WEEE sector has largely, but not universally, focused on recycling rather than reuse.  That needs to change.  The circular economy is a vital way in which we can deliver outcomes to tackle the climate crisis.  Increasing levels of repair and reuse of appropriate products saves embedded carbon and improves material efficiency.  And although some product categories are more amenable to reuse and repair than others, regulatory mechanisms that actively encourage more reuse would be very beneficial.

Household WEEE collections

Some will inevitably object to the proposal that consumers should have access to household collection of WEEE.  And yet, collection from the home makes it far more likely that repairable product will be returned into the WEEE system.  This is because by the time it is collected from a household waste recycling centre, most electrical products are irremediably damaged.  And if implemented correctly, this change can largely rely on existing vehicle movements, thus minimising any additional carbon emissions – and indeed producing carbon savings by increasing the level of reuse.

Eco Design

There are many producers who may push back against including eco design requirements within WEEE.  That is because the UK already has existing eco-design regulations to drive more resource efficient and energy efficient products and so including similar requirements within WEEE risks over complicating the system.

Regulation of online marketplaces

Any objections to the proposals to better regulate product sold via online marketplaces will probably be limited to a few online marketplaces.  When Defra first mooted the proposal for waste packaging, a remarkable 95% of respondents supported the suggestion that online marketplaces take financial responsibility for the packaging of (imported) products sold via their platforms.  It seems very likely that similar changes for WEEE will meet with near universal support.

Responding to the Consultation

The Consultation will run for 12 weeks. Recolight will be working closely with our Producer Members to ensure that changes will work well for the lighting industry.