Anthesis’ Senior Consultant Mark Sayers takes a big picture look at the impact of the changes in the WEEE Directive. He asks how prepared the Electrical and Electronic Equipment (EEE) supply chain is for a shift in product and waste classification, and identifies the four big challenges faced by companies operating across Europe.
It’s happening already – the UK is about to reach a fork in the road on product compliance and waste legislation. Will it slow the way technology evolves, or impact the way we consume more of the latest tech to enrich our lives?
The EEE sales data from UK producers shows we are generally buying more electricals, most which will have been imported from outside the UK. Until I became involved in the WEEE Regulations 10 years ago, I was more interested in the latest features and safe delivery than supply chain and product compliance. But the proposed changes to the UK WEEE Regulations table options that could cause a huge impact on producers and with that, changes in financing and end of life management that could trickle down to consumers and businesses users.
The EU have already signed off the blueprint in the Directive to change the way the European WEEE system works. Although timing in 2019 adds to the complexity of UK implementation, our importers, manufacturers and re-branders, plus those with previously exempt items (including luminaires in households such as adjustable bedside or desk lamp, other electrical products not previously falling within 10 categories) as well as waste management firms collecting material that will be classified as WEEE, will need to consider the implications on their operations and re-budget accordingly before any changes are transposed into UK law.
Main challenges to the new WEEE directive
I believe the main challenges faced by UK and European producers will be:
- Product classification – how to adopt a change in classification of products from 10 to 6 categories; with minimal upheaval to producer costs or waste stream separation for producers. Despite this, there could be significant differences between the UK and European compliance systems if EU continue on anticipated trajectory (move to 6 dimensions based categories), and the UK preferred option is adopted (retain 14 categories).
- Inclusion of previously exempt products – unless an electrical product is specifically exempted, then it is assumed to be in scope. The inclusion of previously exempt products coming into scope is likely to bring new businesses into the WEEE system for the first time. Will this spread the burden or add more demand to the system?
- Impact on budgets – a year ago in a stakeholder meeting, we thought an adoption of 6 categories was most likely for the UK. However, time, circumstances and cost modelling have moved on and the UK looks most favorably to retain the 14 categories with a protocol behind, which will bring the most stability with lowest impact on producer market.
- Recycling costs – waste holders may suddenly find themselves with increased WEEE recycling costs; waste classification is complex and those in the many industries previously outside the scope of WEEE Regulations could find themselves with more administration and separating more waste, otherwise they risk paying for the mixed loads to be sorted elsewhere.
Changes to electrical waste cost recovery
Changes are not just of a technical nature. There also is a cost recovery exercise underway to plug a shortfall in Environment Agency resources. The current consultation seeks feedback on distribution of Regulator operating costs to producers, compliance schemes and recyclers. However, this is only those with registered operations in England.
The Environment Agency funding shortfall is significant, and costs recovery will ultimately trickle down to producers and waste holders unless schemes and recyclers choose to absorb the increased overheads. Those operating from Wales and Scotland would not be affected by the regulator fees changes because there is no apparent shortfall in these regions, so fee increases are likely to upset English based businesses who are extremely cost sensitive.
As we stand, the certainty and impact on the market is quite bespoke based on differing adoption between EU and post exit UK, not to mention product type and classification. Unfortunately, there isn’t a one size fits all answer to the impact of these changes, however one thing is certain: planning and preparation is essential to get ahead of change and the competition.
What can Anthesis do to help?
If the changes affecting your business are not clear, you need to put forward a budget for changes in the Regulations, or simply better understand the impact on your business compliance both here and in Europe, Anthesis can assist.
We have a team with extensive expertise in electricals, EPR and resource efficient supply chains, including product stewardship and take-back. Recent projects have been centered around EEE and packaging, including policy research, development of strategies for improving recycling, and implementation of takeback schemes.
For further information on the WEEE, product compliance, or the broader Extended Producer Responsibility topic, please get in touch with either Mark Sayers or Richard Peagam.