Waste MattersRegulation, Opportunities &

Achievements

WEEE – A short post-implementation review

Mark Hadley

Original Aims

• WEEE Directive introduced into UK law in January 2007.

• Aim - reduce the amount of EEE being produced and to encourage everyone to reuse, recycle & recover it.

• Aim - to improve the environmental performance of businesses that manufacture, supply, use, recycle and recover EEE.

Why have a WEEE Directive?

• Reduce the overall amount of WEEE being deposited in landfill (5-8% year on year increases in EU).

• Create a separate WEEE waste stream, ensuring it’s processed, accounted for & reported.

• Fastest growing EU waste-stream 2005.

Why not have a WEEE Directive !

• Essential counterpart to RoHS Directive for

Pb, Hg, Cd, Cr,

PBB and PBDE

• Municipal Collection costs for WEEE pass to PCS & therefore to producers/consumers

Chronology of WEEE

• Feb 2003 > EU Directive 2002/96/EC Issued.• Aug 2004 > WEEE Directive Implementation Date• Jan 2007 > WEEE (Amendment) Regs. SI 2007:3454

passed into law in UK• July 2007 > UK Household & Comm. Producers in PCS• Jan 2008 > EC compliant in all Member States• Dec 2008 > EC proposes revision of WEEE Directive• Jan 2010 > WEEE (Amendment) Regs. SI 2009:2957• Jan 2012 > Proposal debated by Euro Parliament for a

Re-cast WEEE Directive.

WEEE Collected since 2007

Total WEEE Collected 2007-2011

0

100000

200000

300000

400000

500000

600000

2007 2008 2009 2010 2011

Year

To

nn

es C

olle

cted

Non Household

Household

Total

Predicted EU Increase in WEEE Vs Actual Collected Tonnages UK

Total WEEE collected, Vs predicted year on year increase

0

100000

200000

300000

400000

500000

600000

2007 2008 2009 2010 2011

Year

To

nn

es

Total

annual 5%increase

annual 8%increase

EEE Vs WEEE

EEE Produced Vs WEEE Collected

050

100150200250

300350400

450500

2007

(3)

2007

(4)

2008

(1)

2008

(2)

2008

(3)

2008

(4)

2009

(1)

2009

(2)

2009

(3)

2009

(4)

2010

(1)

2010

(2)

2010

(3)

2010

(4)

2011

(1)

2011

(2)

2011

(3)

Years by Quarter Year

Th

ou

sdan

s o

f to

nn

es

PCS Declared EEE

Collected WEEE

Where’s the missing WEEE?

• Non-obligated WEEE not counted (scrapyards).

• Cannot separate small items from general domestic waste

• Illegal export of WEEE• No match up between historic

rates of EEE placed on market

• Appliance lifetime issue• Appliance weight reduction

Problems at Inception - Lateness

• Directive adopted in 2003, but EU compliant only by Jan 2008.

• In the UK, there were three separate consultations, delaying commercial preparedness.

• Costs of establishing PCS system increased by delays.

• Late implementation of the EA Settlement Centre (Clearing House).

Problems at Inception - Complexity

• Although Directive only has 19 Articles, implementation left to Member States many of which had operating systems already.

• Exclusions – EEE installed in trains, planes & automobiles outside Directive.

• Integral Parts – large stationary tools excluded• Some wastes fell within scope of already

implemented waste legislation (ELV), or

impending legislation (Batteries Directive) 2010

Mechanisms for Compliance

• Actual compliance varies across Member States, two aspects:

>Joining a PCS (mandatory in UK but optional in most EU) >Registration with the Government usually done by PCS, but in 11 countries, it’s a separate process.• Imagine you are a Producer

manufacturing/placing product in all 27 Member States!

2007 – 2010 The first 3 years

• Day 1, WEEE Day (01.07.2007*)• The new PCS market.• Double counting, the problem with

‘Evidence Notes’• Public awareness• Intentional over/under collection *Household Waste Collections.

Day 1, ‘WEEE Day’ (01.07.2007*)

• Substantial number of PCS’s did not have signed contracts with Local Authorities.

• Service collections have to start immediately, or old collections continue.

• Capex involved in scaling up for contracts by recyclers, training and operational demands.

The New PCS Market

• 37 PCS are approved by Environment Agency & SEPA, which one should producers join that is most appropriate for them?

• All EU Member States have one or more national schemes, but all are fee paying.

• Most PCS operate in one country, but a few are EU wide (ERP and RENE).

• Most countries have a couple, only Germany and UK multiple PCS’s and Holland where the scheme was based on WEEE categories!

Double Counting

• Once obligated WEEE arrives at the DCF it awaits collection by appointed collector for PCS.

• Evidence notes only issued on treatment, recovery or recycling or WEEE at the AATF.

• However, some WEEE passed to a AATF, then on to a ‘final’ processor resulting in double counting of the tonnages.

Public Awareness

• April 2005 launch of the RSA ‘WEEE Man’ premature.

• Initial launch at County Hall, syndicated to 400 TV stations worldwide.

• Moved to Bristol Docks with seminars and RSA WEEE Man website & schools programme.

• Permanently housed now at Tim Smit’s Eden Project.

Public Awareness

• 2009 survey, ERP found that 84% of respondents cited public awareness a major problem.

• WRAP awareness campaign Dec 2008 (18 months after WEEE) not very successful.

• Following selective local authority campaigns using radio and TV, collections increased by 30% (London Remade).

Intentional over/under collection WEEE

• PCS required to balance producer obligation/collection tonnage.

• Producer group supported PCS’s such as Repic failed to get DCF tonnages required, whilst waste management-derived PCS’s got the tonnages, but few producers.

• Judicial review 2009 confirms over-collection unlawful, leading to PCS’s encouraged to agree mutual balancing arrangements in advance.

2010 Amended the WEEE Regulations

• Streamlining of evidence process – AATF’s and AE’s issue evidence of WEEE received, rather than WEEE treated, thus reducing double counting.

• Approved PCS no longer have to apply every 3 years for approval.

• New PCS approvals are now ‘open-ended’ based on operational rolling plan each year. No approved plan = no approval.

The RECAST WEEE Directive

• In Dec 2008 EC proposes revised Directive.• Will involve clarification of producer

responsibilities • Give consumers positive involvement in

ensuring more EEE goes to collection facilities• Will count in WEEE from all stakeholders, rather

than just PCS route, impeding illegal exports• Will set new ambitious collection targets,

possibly doubling amount currently reported as collected. (Current target 4Kg per europerson)

IT Equipment – A Case Study

• There are 10 categories of WEEE• Cat 3, IT & Telecommunications

equipment.• In 2010, 206k tonnes placed on

market but only 35k tonnes collected by PCS.

• Much of the missing waste went direct to processors from the businesses themselves or specialised collectors due to value.

…and finally

• Producers were charged between £40-£50m for 2010 compliance period.

• Under UK Regulations producers not charged actual cost of recycling.

• Prices agreed between PCS and WM companies acting behalf of LA’s.

• Hidden & complex price setting means recycling costs have fallen, due to rise in value of commodities

• WEEE estimated to have a overall net value in 2010!