EA warns batteries schemes against complacency

The Environment Agency has warned the UK's batteries producer compliance schemes against complacency over their ability to reach next year's waste portable battery collection target, despite their “encouraging” performance so far in 2010.

As it revealed that all six schemes had their operational plans for the three years from 2011 to 2013 approved at the end of last month, the regulator stressed that next year's interim collection target of 18% is almost double this year's 10%.

And, the Agency's project manager for batteries, Bob Mead, told letsrecycle.com that, while the 2010 and 2011 targets were not statutory, if schemes were to miss their goals in those years, the EA would give “serious thought” to their approval, stressing that “none of us can allow schemes to fail in 2012.”

While figures for the first two quarters of 2010, published last month, showed a waste portable battery collection rate of 12.58% (see letsrecycle.com story), European law requires the UK to reach a 25% collection goal in just two year's time.

In light of the increasing targets, Mr Mead said: “I am as confident as I can be all schemes will meet this year's target but with the caveat that next year's target is twice as big so no-one should be complacent.”

Operational plans

Mr Mead explained that the six approved schemes had been required to submit a range of information in their operational plans by the end of August, such as their expected membership, how they planned to meet those members' collection obligations and financial detail on how the scheme was run.

“We particularly looked at how schemes plan to get from their performance this year, which looks encouraging, to the 18% target,” he said. “How they're going to expand collections networks and what they're going to do about communications – because I don't believe simply putting more collection containers out there will do it.”

However, Mr Mead said the schemes had no regulatory obligation to work together on awareness campaigns, explaining that, when considering that aspect of their operational plans, “our focus was on how does this deliver your obligation?”.

“What I have said to schemes is there might be benefits in them co-operating to do some collective awareness-raising,” he added, but noted hesitancy among some schemes to spend money that might benefit their competitors.

In terms of checking the scheme's plans, Mr Mead also revealed that the Agency had had to ask all six for more information, explaining: “Last year we all had to accept there was a degree of uncertainty. We felt this year we should be pushing them a bit more.

“There wasn't enough detail – a few too many generalisations,” he added.

Seven schemes were originally approved in 2009 for the first year of the UK's waste portable battery recycling system (see letsrecycle.com story), although only six began the 2010 compliance year, after DHL withdrew its scheme and it's members moved across to ERP (see letsrecycle.com story).

Trading

Commenting on the trading of recycling evidence between schemes, Mr Mead stressed the differences between the batteries system and that for WEEE, noting that “the fundamental difference with WEEE is each scheme has a very clear target and it has to go out and hit that target from scratch.

“There's no parallel to the designated collection facilities network,” he said. “The market mechanism that caused friction in WEEE doesn't exist in batteries.”

The batteries regulations put a nominal cap on trading, meaning that schemes should not meet more than 10% of their obligation through trading.

And, Mr Mead said that, for 2010 so far: “I believe there's been no trading at the moment and the evidence suggests schemes are all in line to meet their obligations from their own efforts.”

Missed targets

With the collection figures achieved for 2010 to date, Mr Mead said there was “no reason” to think any scheme would miss its goals for this year, but stressed that, while the targets for 2010 and 2011 weren't legally binding, “they are hard in the sense that we expect them to meet them”.

“The [operational] plan should show they have a reasonable approach to meeting the targets,” he said, explaining that, if they were missed, “we'll ask the scheme in question to explain what went wrong and what they're doing to correct it”.

He added: “If a scheme was to miss by a long way, which I don't expect to happen, we'd have to give serious thought over whether we can allow the scheme to continue to be approved.”