FAQs

Recolight takes on the legal responsibility of its producer members to comply with the WEEE Regulations through a binding agreement.

Recolight is a not-for-profit company and passes on, to its members, the costs and financing it incurs each year in carrying out the various tasks of its business plan on behalf of the members.

For example:

• Recycling services.
• Investment in marketing to raise awareness of the need to recycle and the Recolight brand.
• Administration costs and ensuring a viable financial base for the compliance scheme.

Our cost recovery method is to calculate a flat charge per lamp type which is then applied equally to all members.

This ensures the process is equitable to all and kept simple and cost effective.

A producer’s obligation under the WEEE Regulations

The WEEE Regulations state that:

“Producers of electrical and electronic equipment (EEE) are responsible for financing and ensuring the disposal of end-of-life products in an environmentally sound way arising from both household and non-household users.”

If you put a product in scope of the WEEE regulations onto the UK market by any of the following:

• Manufacture and sell electrical and electronic equipment under their own brand.
• Resell, under their own brand, equipment produced by other suppliers.
• Import electrical and electronic equipment on a professional basis into an EU Member State. This includes imports into the UK from other EU member states

You must join a compliance scheme which will meet your WEEE responsibility for you by financing the safe disposal of all products at end-of life.

Recolight, who will manage this responsibility on your behalf.

It is your obligation as a producer to:

• Mark all EEE with the wheelie bin symbol
• Declare WEEE number to distributors
• Provide recycling information of all EEE
• Sign an annual declaration of compliance

A full list of your responsibilities can be found on the Environment Agency website.

Administration and reporting

• There is an initial process of registering on the Recolight Black Box secure website and returning signed copies of the Scheme Rules Agreement.
• The monthly data update will only take a few minutes each month via the Black Box.
• Thereafter Recolight will take care of your legal obligations on your behalf and provide information on an as-required basis to support your business.

All schemes must report data in a standard format to the enforcement agencies and we have designed our own formats in the same way as a matter of efficiency.

To demonstrate to the enforcement agencies that our data is correct we audit our members. This is done on a random basis and no more onerous than necessary to achieve the objective.

Black Box timeline of events

Monthly

Each month you are required to advise Recolight of your placed on market units and their aggregated weight. An accurate declaration must be made between the first and fifteenth day of each month, following the month end.

Environment Agency rules for declaring are:

• B2B All goods placed on market within any calendar year must be declared no later than 15 January of the year following.
• B2C All goods placed on market must be declared quarterly.
• If your company is declaring B2C, then regardless of unit quantity, you must declare these figures quarterly.

Annual confirmations

An annual confirmation is a confirmation of the information your company has supplied to us throughout the previous year, summarised on a single page document.

You carry out this process after the 16 January each year and have up until the 15 February to complete. It takes just a few minutes.

This is an EA requirement.

Annual Declaration of Compliance

The annual declaration process starts around the first week of September each year, and you have until 16 November to complete. All members are emailed a document with questions; this must be printed, answered, signed by a director or senior manager and then scanned or posted to Recolight.

The Environment Agency for England and Wales, Scottish Environment Protection Agency and Northern Ireland Environment Agency are responsible for ensuring that all eligible producers and suppliers register with a compliance scheme.

The compliance scheme is then responsible for the producers’ obligations and for getting data from its members on EEE put onto the market and for reporting on WEEE collected and recycled.

In order for us to demonstrate to the enforcement agencies that our data is correct we audit our members. This is on a random basis and no more onerous than necessary to achieve the objective.

Do Recolight enforce Regulation 9.2?

Regulation 9(2) was a clause in the WEEE regulations that allowed producers to pass all their financing obligations for recycling on to their B2B customers – but only if there is a clear agreement between producer and the final business end user.

Given the complex, multi-level distribution networks that exist in our industry, we were convinced that this didn’t work for lamps. By passing the liability onto your customer

• you are giving them a problem – how to recycle,
• rather than a solution – recycling available through Recolight.

Consequently, the Recolight membership agreement does not allow producers to use regulation 9(2).

The new WEEE regulations clarify 9(2)

12(2) sates:

(2) Nothing in paragraph (1) will prevent a producer from concluding an agreement with users other than private households to make alternative arrangements between themselves to finance the costs of the collection, treatment, recovery and environmentally sound disposal of WEEE.

The change is to make it clear that the agreement must now be between B2B end users and producers.  So the old reg 9(2) approach can now only work where there is a direct contractual relationship between the Producer and the B2B End User.  It therefore cannot apply to sales through intermediaries (eg Wholesalers or contractors).

Businesses buying lamps from Recolight members which are then exported outside of the UK are able to obtain a partial refund of the purchase price.

As a compliance scheme, Recolight is unique in organising refunds from its members for exports of EEE.

Recolight has no involvement in the price paid for the lamps (and how much, if any, of Recolight’s WEEE costs to its member are included in that purchase price) – this is entirely between the producer and the buyer.  However, Recolight is able to administer a refund mechanism on behalf of the relevant Recolight member, unless that Recolight member has opted out.

Please note that exported lamps will usually need to be re-declared as EEE in the country into which they are sold. This is because they will contribute to the waste stream in that country.  It is the responsibility of the new importer in that country to declare them as EEE.

How to apply for a refund request

Recolight’s web-based system allows the members’ customers to apply for an export refund.  You will be asked to provide appropriate evidence that the products have been sold and exported.  Where necessary, Recolight will separately obtain confirmation of the WEEE costs included in the purchase price from the Recolight member.

Refunds can be requested through our Black Box system.

If you need help completing your refund request, or are an existing refund requester, and need a new copy of the support manual,

please email [email protected]

The Distributor Takeback Scheme (DTS) enables distributors to discharge any household take-back obligations that they might have rather than provide in-store take-back facilities themselves. This mainly involves directing customers to the nearest local authority recycling centre, which membership funds of the DTS contribute to.

Wherever possible Recolight would encourage distributors to provide the most simple solution for customers to recycle their lamps to help encourage more recycling and reduce the amount of harmful waste going to landfill.

Providing in-store take-back avoids the temptation for a household user to put waste lamps in with the general household waste if the journey to a local authority site is difficult or inconvenient.

Recolight have Bulbstore containers across the UK, working in partnership with retailers and Local Authorities, helping to make it easier for consumers to recycle.

Scientists at the Health Protection Agency have reviewed the potential health effects of mercury exposure from broken fluorescent lamp. They found the exposure is likely to be very small – and much lower than from other broken mercury-containing products such as some types of thermometer and barometers.

Professor Virginia Murray, Consultant Medical Toxicologist, said: “Compact fluorescent lamps contain a tiny amount of mercury – roughly enough to cover the tip of a ball point pen.  A small proportion of this could be released into a room if the bulb is broken, but this does not pose a health risk to anyone immediately exposed.

“As a precautionary measure, the Health Protection Agency advise that the room should be ventilated and the bulb cleaned up and disposed of properly.”

The amount of mercury in fluorescent lamp is between 1.2 to 4 milligrams even though the amount is very small, you should still follow the following guidelines given, by the Health Protection agency, to safely remove the broken bulb.

Preparation

Vacate the room and keep children and pets out of the affected area. Shut off central air conditioning system, if you have one.

Ventilate the room by opening the windows for at least 15 minutes before clean up.

Do not use a vacuum cleaner, but clean up using rubber gloves and aim to avoid creating and inhaling airborne dust as much as possible.

Cleaning up

On hard surfaces sweep up all particles and glass fragments with stiff cardboard and place everything, including the cardboard, in a plastic bag. Wipe the area with a damp cloth and then add that to the bag. Household cleaning products should be avoided during clean up despite the very small amount of mercury involved.

On soft furnishings and carpets, do not use a damp cloth, just sticky tape to pick up small residual CFL pieces or powder from soft furnishings and then add that to the bag.

Disposing of the bulb

The plastic bag should be reasonably sturdy and needs to be sealed, but it does not need to be air tight. The sealed plastic bag should be double-bagged to minimise cuts from broken glass.

The bag with all broken pieces and cleaning items should then be taken to your local council recycling centre, where you will find a special section for WEEE.

Procedures to record the movement and collection of hazardous WEEE vary across the four UK environment agencies:

Environment Agency for England

Scottish Environment Protection Agency

Northern Ireland Environment Agency

Natural Resources Wales

Tracking waste lamps

Consignment notes (waste transfer notes) are issued in multiple copies, including sheets for the end user, (producer of the waste), the transporter and the recycling plant. These are free in England and Wales, but small charges apply in Scotland and Northern Ireland.

Storage and Movement of waste lamps

Licenses, permits and exemptions are in place for the storage and movement on lamps on and between your sites.

Again, these vary across the UK. For some Environment Agencies there is no cost for you to apply for a license to store your lamps and no charge for a waste carrier license.

The Paper Work information outlines the processes along with any costs associated.

Recolight offer a free container, collection and recycling for those collection over 1000 lamps within three months. We have other free recycling services for those who collect less than 1000 lamps – and also for on off collections. We can provide this as a free service as we are funded by our members, the lighting industry.

Our service level agreement outlines additional costs you may incur for a

• failed collection,
• low weight,
• excess wait time,
• contamination in container.

These charges are passed onto us and therefore our passed onto those collection points who fail to meet our terms of service.

The four UK Environment Agencies have process in place to monitor the movement, storage and collection of waste lamps. Costs for licenses, permits and consignment notes vary for all four, and some are free. Refer to our section: The Paper Work where you can find information about additional costs.