Defra launched a consultation on the compliance fee methodology for waste electrical and electronic equipment (WEEE) yesterday, 12 October.
Two proposals for the WEEE compliance fee 2020 have been put forward by compliance scheme Valpak and the Joint Trade Association (JTA).
Defra’s introduction to the consultation reads: “The WEEE Regulations establish a system of annual collection targets that are imposed on producer compliance schemes (PCSs).
“The Secretary of State has discretionary powers to approve a compliance fee methodology as an alternative form of compliance payable by PCSs that fail to achieve their collection target.”
Defra confirmed in June that any 2020 compliance fee methodology for WEEE would need to take the impact of the coronavirus pandemic into account (see letsrecycle.com story).
As part of the consultation, comments are invited on whether George Eustice, the Secretary of State for Defra, should set a compliance fee for 2020. The consultation can be accessed here.
The compliance fee methodology and compliance fee scheme operator approved by the Secretary of State will be announced no later than mid-February 2021.
Under the proposal put forward by Valpak, compliance fees would be calculated separately for each scheme wishing to use the fee and for each WEEE stream, from a combination of three principal elements.
The first of these would be a base cost per tonne, calculated from the weighted average collection and treatment costs of local authority collections of all schemes using the fee.
The second element of the Valpak scheme would be a standard amount per tonne to reflect the direct scheme operational management costs. In previous years, this was proposed at £3.50 per tonne, which Valpak says “continues to be broadly representative”.
And, the third element would be an allowance for schemes that fall short of their targets, in any stream, as a direct result of the reduction in national collections caused by the Covid-19 pandemic.
There would also be a £2,000 participation fee for each compliance scheme wishing to use the compliance fee. The fee will act as a contribution towards audit and administration costs, Valpak says.
And, collection and treatment costs would be escalated by a factor related to the degree of scheme shortfall against the national target set by the government in each stream, so that a greater fee is payable for a shortfall which is more significant compared to the government’s requirement.
The JTA’s proposal is based on its mechanism for 2019, which was the system eventually approved by ministers. JTA’s proposal for 2020 has three “one-off modifications”. These modifications are intended to reflect the impact and potential future impact of the Covid-19 pandemic on UK household WEEE collections.
The first modification would be that a producer compliance scheme would only pay a fee if its collection rate in any WEEE stream was below the national rate of actual collections for that stream.
The second modification would be that producer compliance schemes would be remunerated for tonnages collected above their Covid compliance fee thresholds in that stream.
And, the final modification would be that, for all fee calculations, irrespective of whether national collections reported by all producer compliance schemes for a stream are above or below the national targets set by Defra, only the normal escalator would be applied.
The JTA says it would engage the executive director of Material Focus, Scott Butler, to work with Mazars during the operation of the fee to ensure it was administered and managed in a smooth, independent and professional manner.
The proposal submitted by the Joint Trade Association for 2019’s WEEE compliance fee was approved by ministers in February 2020 (see letsrecycle.com story).
Administered by accountancy group Mazars, the proposal was accepted following some modifications agreed between Defra and the JTA.
The decision to approve the JTA’s proposal was taken following a consultation which began in October 2019 (see letsrecycle.com story).
As is the case this year, proposals for the fee were put forward by the compliance scheme Valpak and the JTA, a group of product-focused trade associations who work on policy issues around producer responsibility.
2019 was the third consecutive year in which a JTA-proposed methodology was used to determine the fee.