EEF Response to Final Consultation on Implementation of WEEE and ROHS Directives

Summary of Key Concerns

• A major concern for EEF is that the timescale for setting up the NCH seems completely unrealistic. The NCH will play a fundamental role in facilitating producers to meet the requirements of the WEEE Directive. It is therefore, crucial that no short cuts are taken and that the NCH is set up to run as efficiently as possible from the outset.
• Of additional concern is the continued lack of detail on how much it will cost producers to fund the NCH. This was a concern we expressed in the second consultation that was held earlier in the year. Producers need to be able to budget for the extra costs that compliance with WEEE will bring at an early stage.
• Government must not place ad-hoc arrangements on producers which are implemented as a stop-gap to address the failure of government departments to adequately project manage the implementation of this policy.