Issue brief - WEEE

The WEEE Directive makes producers of Electrical and Electronic Equipment (EEE) responsible for the recovery and recycling of this equipment at the end of its life. There have been a number of proposals for implementation, which have had to be revised due to serious problems.

After a number of delays, it was announced on 15 December 2005 the DTI announced that implementation plans for WEEE would be ‘immediately reviewed’. This review was started in January 2006, and a new team was put in position at the DTI to take this forward. We have seen the results of this review, and have taken part in a period of informal consultations with the DTI.

The latest proposal uses compliance schemes as the main way to deliver implementation. All companies must register via a compliance scheme and the Environment Agency (EA) will essentially then only have to regulate the compliance schemes rather than every individual producer. Other ideas that have been discussed include the trading of WEEE recycling notes (WRNs) and the allocation of individual Designated Collection Facilities (DCFs) to the ‘largest’ producers in order for them to discharge their obligations.

One of the key areas of debate is with a ‘visible fee’ policy, that would allow retailed to recover recycling costs for historical items. The Minister in charge, Malcolm Wicks, has ruled that there will not be a visible fee introduced as part of the implementation, and has excluded this from the consultation on the implementation of WEEE, which closes on 15 October 2006.

EEF retains a number of reservations about the WEEE Directive, and as a result we will:

· continue to advocate a visible fee wherever possible

· ensure the needs of EEF’s members are contributed to the consultation, particularly with regards to arrangements for simply disposing of waste electrical equipment on a general engineering site

· raise other concerns we have with the registration process – in how much time industry is given to prepare and gather the necessary information. It is important that this time is not squeezed due to DTI not being sufficiently organised.

· focus on the difficulty of scope issues (e.g. companies actually working out if their products fall into the scope of the Directive)

· keep a close eye on the consultation process – how open it is, what manufacturing involvement is, and monitoring the timescales (some of which have been very difficult due to very short timescales).