BIS to review WEEE evidence trading

Reprocessors have warned that a new evidence note trading system for waste electrical and electronic equipment (WEEE) will significantly add to their administrative costs.

The changes involve the transferring of evidence between compliance schemes via operators of Approved Authorised Treatment Facilities (AATFs) and came into force on January 1 2014.

The operators of the AATFs typically receive WEEE from civic amenity sites on behalf of compliance schemes and often shred the electrical items for recovery and recycling,

Under the old regulations, AATFs were required to fill out one evidence note for every tonne of WEEE processed, which would be issued to the compliance scheme that had supplied the WEEE. Schemes collecting a surplus of WEEE compared to the amount they were required to collect could trade any surplus evidence notes to schemes that had not collected enough.

Direct trading between schemes has been outlawed under the new regulations by BIS partly because it believes that the new system will reduce costs.

Guidance

Guidance on the new regulations, which was published late in 2013 (see letsrecycle.com story), states that AATFs are now responsible for ensuring that evidence notes are issued only to the producer compliance scheme that will count the evidence towards its target.

The guidance states: Transfers of evidence between schemes on the Settlement Centre in order to ensure all PCSs are able to meet their financial obligations are no longer needed under the new system. Sub contracting for collection and treatment between schemes however will, it is assumed, remain a key feature of the new system. In such circumstances the evidence should be issued by the first receiving AATF directly to the PCS that will ultimately count the evidence towards their collection target.

According to AATF operators this could lead to additional administrative costs, as they will be required to change existing IT recording systems and complicate the issuing of evidence notes. They also claim it could also lead to a delay in the reporting of quarterly recycling data as reprocessors will not be aware of the ultimate owner of the evidence when it has been generated.

AATFs

Justin Greenaway, contracts manager at Kent-based WEEE reprocessor SWEEEP Kuusakoski commented that the implications of the guidance had only recently become clear.

He said : For the last five and a half years WEEE recycling evidence has been attributed by an AATF to the WEEE compliance scheme that they are contracted with to carry out a recycling service.

Waste data management systems and accounting software has been developed, fine-tuned and perfected during this period. Now with negligible notice the fundamentals of a tried and tested reporting system is being jeopardised.

The Department for Business Innovation and Skills (BIS) is now seeking views on the issue to inform its policy decision over how to address the concerns.

Speaking to letsrecycle.com, a BIS spokesman said: We have received a number of helpful comments from stakeholders on the question of trading of evidence notes between compliance schemes under the new WEEE Regulations. We are considering the arguments for and against carefully and will confirm our position in due course.

Compliance schemes

Adrian Hawkes, director of policy at producer compliance scheme Valpak, added that there could still be a limited scope for evidence trading between schemes under the new system, with the new regulations safeguarding against the high evidence prices seen under the previous regime.

He said:Evidence trading as it was in place in 2013 would not be permitted in 2014. What we would say is that we would understand why the government wishes to take that out of the system because it was credited as leading to expensive evidence prices in previous years.

Having said that, we appreciate that you dont want to encourage high prices, but we think with other changes such as the lack of a 100% market you reduce the risk of that leading to high cost anymore.

However Mr Hawkes suggested that BIS might consider adjusting the guidance to permit limited trading between schemes. His rationale was for where sufficient arrangement were in place to obtain WEEE but faced an unexpected shortage, evidence might be bought from another scheme.

He explained:With that in mind, we would say there are some benefits for having a limited scope to transfer between schemes, the vast majority we would think would be anticipated in advance and could be set up early in the year but there are instances when this might be quite important so the ability to make adjustments would be helpful.

BIS is expected to provide further details on its decision on the issue in the coming weeks.