The Waste Electrical and Electronic Equipment (WEEE) Directive became national law across the EU member states in August, although in the UK and most other countries the necessary regulations are not yet in place. In fact the draft British regulations are out for consultation at the moment (consultation closes at the end of October) and there is then a frighteningly short timetable for implementation. The industry is expected to set up and run a national clearing house (NCH – of which more later) under a contract to be let by government, possibly by competitive tender – this is supposed to be in a position to collect data by January 2005, and the whole system is to be operational by August 2005.
Although the WEEE Directive is an essentially simple piece of legislation, much practical detail has yet to be decided, in the UK and elsewhere. It is evident that there will be a fine line between a practical and affordable scheme that will make a significant difference to the amount of electrical waste being dumped to landfill and an expensive, bureaucratic and ineffective failure, so it is essential that the industry takes this last chance to get the detail right.
The Directive’s aims are simple enough – to stop WEEE arising in the first place, to encourage reuse, recycling and recovery and to improve environmental performance. Like the existing packaging waste regime and forthcoming laws on, for example, end of life vehicles, the rules adopt the ‘producer pays’ principle and the main job of the NCH will be to devise and run a scheme whereby manufacturers finance the bulk of the collection, treatment, recycling and recovery activities. Retailers and distributors will often be the first point of contact for the take-back of old equipment. Producers’ liabilities will be based on market share and the NCH will have to devise a comprehensive reporting system whereby manufacturers can prove that they have collected and treated, or more likely financed, the collection and treatment through some group compliance scheme akin to those that exist under the packaging waste rules, of their allocation. Producers supplying business users will have to finance the costs of waste arising from the supply unless they make ‘alternative arrangements’ with the user – which should create some interesting contract negotiations. Business users can be charged for recycling costs but a central point of the Directive is that domestic users must be able to put WEEE into the recovery stream free of charge. Therefore retailers are obliged to offer free in-store take-back of WEEE where there is a like-for-like sale and also inform private householders of other available take-back facilities (the Directive applies equally to distance sellers, although how that will work out in practice is less than obvious).
It is immediately obvious that there are some hefty IT implications to all this. Somehow, and in short order, the NCH is going to have to create a common network that links not only producers and distributors but also waste carriers, the operators of Designated Collection Facilities (the concentration points for household WEEE not collected through retailers) and recycling/treatment facilities. Consig ments of waste need to be tracked through the system not only by tonnage but by proportions of materials recycled or re-used, and of course the producers or their compliance schemes billed. (An added complexity for producers is that because each EU country will have its own way of complying with the Directive, firms supplying more than one market may have to deal with several radically different approaches.)
If the IT is problematic, the physical logistics are equally so. Few retailers have the space or facilities (or the planning permission) for the long-term storage of waste so this will have to be cleared in uneconomic penny packets. There is not much obvious scope for back-loading. Collection of waste goods from households by firms delivering replacement items is superficially attractive but creates obvious operating difficulties in the multi-drop situation – how do you reach Mrs Brown’s new TV when the back of the van is taken up by Mrs Jones’ greasy old electric cooker. The siting of collection facilities, and indeed of treatment/recycling plants of which there are certainly too few in most European countries, will inevitably be governed more by the NIMBY (‘not in my back yard’) principle than by the requirements of efficient transportation.
All this will add cost. A survey of existing, mostly smaller-scale and more specialised schemes across Europe suggests average direct costs of collection and treatment varying between €0.35 and €0.64 per kilogram of waste equipment, but this is mostly in countries with a well-established recycling culture and infrastructure. A pilot scheme in Edinburgh around five years ago suggested the need for a subsidy of up to e150 per tonne. The truth will doubtless lie somewhere in between, but since the Directive requires the recovery of 4kg of WEEE per head of population per year, the money involved is substantial – the UK government estimates additional annual costs to business in the UK at anywhere between e300m and e600m.
This will also have an impact on business relationships. Although the NCH should ensure manufacturers pick up their share of direct costs it is hard to see where small retailers and distributors are going to recover the additional burden of administration and IT, not to mention physical collection and storage. No doubt the Tescos and Wal-Marts will successfully pass these costs back to the manufacturers in supply negotiations – not many others will manage that.
- Implementation of the WEEE Directive in the UK is less than a year away – it’s too late to change the principles but the make-or-break detail is still to be resolved.
- Consultation ends in October – see the Department of Trade & Industry website (www.dti.gov.uk/sustainability/weee).
- Multinationals need to track other nations’ implementation plans – they won’t necessarily resemble those of the UK.
- Be prepared for a last-minute rush on suitable IT systems.
- Talk to logistics contractors about the physical handling of WEEE.