Electrolink maps out approach to WEEE evidence

The questionnaire – and a letter – come in the wake of the decision by the Department for Business, Enterprise and Regulatory Reform (BERR) that the obligation for WEEE evidence will be based on the evidence issued by recyclers.

In the letter Electrolink, which is part of Wastepack,  has argued that all compliance schemes will have to meet the costs of purchasing all the evidence, were the situation to arise where one scheme did not actually buy evidence for whatever reasons.

In its letter, Electrolink has told the other schemes that “BERR in their joint statement with the EA and SEPA…pointed out that Local Authorities must recover all their costs and Producer Compliance Schemes must meet those costs in full.”

A spokesman for Wastepack compared the system to one where a group of people go out for a meal together and then one can't or doesn't pay and so the group settles the bill.

However, it is unclear how much support there is for the Wastepack interpretation. One scheme said the situation was more like a number of people booking tables in a restaurant and all settling their own bills – if one table didn't pay then the problem was between the restaurant and the customer.

The interpretations are important because Wastepack has more evidence than it needs for its own members and so has a large amount it can sell to other compliance schemes who are short of evidence, in particular the Repic scheme. Wastepack has this higher volume of evidence because it successfully reached agreements with a substantial number of local authorities to take responsibility for the WEEE from their civic amenity sites. It is vital for Wastepack to sell its evidence but the scheme, in a letter accompanying the questionnaire, says that for a number of reasons it cannot give an immediate price for the evidence.

This is explained by Lynne Cullis, chief operating officer for Wastepack, who wrote: “I am sure you will understand that we cannot simply give you a unit price only to find that there was after all a minor mismatch between the obligation and the availability of evidence notes or that not all PCS's decided to comply.

“Therefore we must ensure that all, or as many evidence notes as possible are purchased so that the unit cost is kept to a minimum but in any event the full costs are paid.”

Ms Cullis continues: “The purpose of this questionnaire is simply to determine that the number of tonnes required by each participating PCS is equal to the total number of tonnes available so that the unit cost per note can be kept to a minimum. This questionnaire is not an attempt to inflate the price. The total cost of recycling the WEEE is set out in the contract. Individual site costs do vary but the overall cost is fixed.

“The individual unit costs cannot be fixed until we know how many tonnes are required for each category as there may still be a mismatch between the obligation and the number of tonnes purchased via the settlement centre. The individual unit cost will be calculated by dividing the number of Evidence Notes purchased into the total cost of recycling in each category.”

Tonnes

Compliance schemes are then asked how may tonnes they will require and how they wish to purchase the evidence.

Wastepack emphasised that “the purpose of the questionnaire is to enable us allocate the Evidence Notes and determine the unit cost per category by dividing the total cost by the number of evidence notes sold.”