Restoring the balance when it comes to WEEE
REPIC has been talking to councils about the new changes affecting WEEE, one of which is ensuring a balanced collection system is in place. Philip Morton explainsThe UK WEEE system might be thought to be a fairly simple scheme for local authorities - apply to be a designated collection facility (DCF) and choose a producer compliance scheme (PCS) to remove WEEE from each site. In practice, however, the system has proven to be more complex and many councils have felt that support in navigating the WEEE maze has been in short supply.
To remedy this situation REPIC has been running a series of free workshops for local authorities to provide them with up-to-date information on WEEE legislation, plus help and guidance to understand the options open to them. The workshops have attracted hundreds of council representatives from across the UK since the first was held in 2007, giving each a platform to share their experiences of the WEEE system and best practice among colleagues.
During the most recent round of workshops held this year, one of the most pressing questions thrown up by local authorities was what key changes they needed to know about in the wake of the Government's latest WEEE consultation. The importance of keeping the WEEE system in balance has been reinforced with the proposal of a new scheme approval procedure - PCSs must be able to demonstrate that their WEEE collections currently match (balance) their members' WEEE obligations for 2009.
Plan of action
By July they must be able to show they have plans in place to ensure this will also be the case for the 2010 compliance year. Failure to be able to demonstrate this to the satisfaction of the enforcement authorities could result in a PCS's approval being removed, which would leave their partner local authorities having to make alternative arrangements for WEEE collection.
Large-scale trading of WEEE evidence will no longer be permitted. The Environment Agency has recently issued a statement to schemes which states that, "following legal advice, for the 2009 compliance period onwards, reliance on trading large amounts of evidence is not acceptable". Schemes must therefore adjust their collection plans in advance to demonstrate balance and avoid having to buy or sell large amounts of evidence to achieve their WEEE requirements.
The future existence and operation of the distributor takeback scheme (DTS) system is also to be reviewed. The DTS scheme was set up as a way for retailers to fund the collection of its customers' WEEE at DCFs without having to provide an in-store takeback scheme. Retailers opting out of in-store takeback have contributed to a central fund, which has allowed a country-wide network of civic amenity sites to be upgraded to DCFs. The question being posed is, should the DTS continue, what form should it take and how much funding will be required?
This leads onto another key concern from local authorities - how will their DCF sites be funded if the DTS scheme is abolished? The scheme was introduced in 2007 to cover the first three compliance periods, so the requirement for a second round of funding is being investigated for DCFs for 2010 onwards. The issue of future funding has been raised in the Government's consultation document and while no detailed information is available at present, we believe that discussions are underway between representatives from wider stakeholder groups to reach a decision about the future scope of the DTS.
Councils are also asking what the implications are for them if they are partnered with a scheme that is 'out of balance'. A PCS that cannot demonstrate its WEEE collection arrangements are in balance with its scheme members' obligations risks losing its approval. So councils partnered with such schemes risk disruption to their WEEE services if scheme approval is withdrawn.
Check out capacity
It is therefore important that local authorities check that their PCS has the capacity to take on the estimated volume of WEEE collected at its DCFs, or if it has advance arrangements with other PCSs to balance differences. Authorities can consider changing a PCS partner if it is found to be out of balance. In terms of how it will affect DCF site activities if a council changes its partnered WEEE scheme, I can only speak for REPIC, as all PCSs will have different approaches.
We believe the transfer of a DCF between WEEE schemes should be a smooth process resulting in an uninterrupted service and offer a seamless transfer procedure for any local authority or DCF operator wishing to reassign any of its DCFs. This includes retaining any existing site arrangement and service partners if desired, or alternatively, we can create a bespoke service to suit the DCF's requirements.
Local authorities should talk to their PCS and ask for confirmation of its current level of WEEE collection, how this relates to its members' requirements and its plans for adjustment. Every PCS should have a transparent collection strategy and so can share this information with its local authority partner.
By being proactive, local authorities can maintain continuity of service, continuity of service providers and help to achieve the balance required in the UK WEEE system for the benefit of all stakeholders. There are many options available for local authorities - such as swapping PCS, or the incumbent PCS agreeing to work with a second operator to share the WEEE collection process.
Dr Philip Morton is chief executive of REPIC
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