19 October 2018 by Joshua Doherty

WEEE compliance fee consultation divides opinion

Two proposals have been issued for the 2018 WEEE compliance fee and both include measures to incentivise local authority collections.

The proposals have been put out for consultation by the Department for Environment Food and Rural Affairs which is also asking whether a Waste Electrical and Electronic Equipment (WEEE) compliance fee should actually be set for 2018 – there is an industry expectation that one will be as was the case last year.

Explaining the compliance fee, Defra noted how it its administration is agreed annually and companies that don’t meet their annual collection targets can comply with the 2013 WEEE Regulations by paying the compliance fee instead.

The compliance fee is the backstop to collecting evidence of the recycling of WEEE from authorised treatment facilities

The compliance fee is seen as important because of the level of pressure it puts on schemes to comply with the regulations and organise and obtain sufficient evidence of WEEE recycling of various categories. If they have insufficient recycling evidence, the compliance fee system is a fallback option.

The two proposals both have measures to ensure that schemes which want to use the compliance fees but are not a member of the Producer Balancing System (PBS) must pay more. And, the two ideas have prompted differing views as to their merits.

Consultation

The consultation on the two proposals sees two suggestions, which as in 2017, come from the Joint Trade Association – a grouping of nine Trade Associations in the electronics sector – and from Valpak, the biggest compliance scheme in the UK. A decision will be announced in February 2019.

Targets are usually met through acquiring evidence of recycling for material collected for recycling, much of which is collected from council-run civic amenity sites or through the PBS for those councils which are more difficult.

JTA

For this year’s proposal, along with the PBS extra fees, the JTA also proposed that stream specific, variable administrative costs should be included in the fee calculation.

The JTA proposal said the fee for a scheme to pay should be calculated using the difference between evidence collected against a scheme’s own target, whilst the Valpak proposal says this should be against the national target as this would be fairer.

Also, with regards to admin costs, the JTA says it will change last year’s £3.50 flat fee and introduce more stream specific variable administrative costs.

According to the proposal, this will reflect the weighted average variable administrative cost per tonne incurred by PCS for each WEEE stream when undertaking household WEEE collections, and will include costs such as undertaking audits, managing collections and bidding for LA contracts.

Speaking to letsreycle.com, Susanne Baker of the JTA, explained that the group felt that there needed to be more of a focus on this area, and have worked with consultancy Anthesis to come up with a method.

“Last year there was the £3.50 flat fee but the guidance says it needs to be more stream specific. To calculate this year’s method, we therefore took the data submitted from three streams and came up with an admin cost, and if successful, we have stated that others can also submit their data to Anthesis and this can be changed.

“We were previously concerned about this as it can be difficult to ascertain, but we think our suggestion relates to the costs for collections, and specifically be for each stream.”

ERP, Recolight and REPIC were the three schemes advising the JTA on this proposal.

Valpak

Valpak’s suggestion keeps the £3.50 flat fee for administration costs, while also including extra fees for those outside of the PBS and also including measures to incentivise evidence collected from local authorities.

“We have also adopted a WEEE source adjustment, which incentivises local authority collection”


Adrian Hawkes
Valpak

However, a key difference is that the methodology used for working out the costs. Valpak say this should be the total shortage of tonnage overall against the national target, whilst the other proposal says this should be set individually, which some have said could favour the bigger schemes.

Speaking with letsrecycle.com, Adrian Hawkes, policy director at Valpak, explained some of the key points of its proposal.

Our proposal is similar to previous years but building on how we operated and slightly refined, using key principles such as a calculator based on tonnage shortfall, and also the fact that escalators don’t apply to the first part of tonnage if the UK misses its target as a whole.

“We also have suggested uplift on schemes not on the PBS, and also an administration fee, which was previously different but is now standardised.

“We have also adopted a WEEE source adjustment, which incentivises local authority collection, the whole idea of the WEEE regulations is to encourage la collections yourself and not rely on others. That’s the idea behind them.”

The JTA has seen its proposals nominated in three of the previous four years 2014, 15 and 17, while Valpak’s proposal was in 2016.

Reaction

There was a general consensus among many compliance schemes that both of the methods were very similar.

Robbie Staniforth, commercial chair of Ecosurety, said there are good and bad sides to both proposals.

“I think the problem with both proposals is that they prioritise collections from local authorities. Nowhere in the WEEE Regulations does it actually say that local authority WEEE is better or more valuable that WEEE from elsewhere,” he explained.

Mr Staniforth said: “Other aspects of the proposals are good. I think those who are not a part of the PBS and want to use the scheme should pay more. With regards to the JTA scheme in particular, I think this shows a form of big-scheme bias. There is no reason why the collection of WEEE should be made easier for the bigger schemes.”

“We support the JTA proposal, which we believe best meets the criteria set by Defra”


Mark Burrows-Smith
REPIC

Welcomed

Mark Burrows-Smith, CEO of REPIC, which describes itself as the largest WEEE producer compliance scheme in the UK, said he welcomed the proposals.

“It is good that there are alternative proposals for Defra and the industry to consider. We welcome the consultation and will be responding to it in due course. We support the JTA proposal, which we believe best meets the criteria set by Defra including taking account of current market conditions.”

This was echoed by John Redmayne, managing director of the European Recycling Platform (ERP), which also advises the JTA, who said that while the two are similar, this isn’t necessarily a bad thing.

“From my initial reading they look pretty similar. If imitation is a good form of flattery, the JTA should be very pleased.

“Since the start, the two proposals have always been somewhat similar, and there has been a lot of convergence, which isn’t surprising, but it shows that government thinks the mechanisms are roughly in the right place at the moment.”

Local collection

Other schemes however, thought the consultation hasn’t addressed some of the key issues facing the industry.

Lynne Cullis, chief executive of the Wastepack Group, said the proposals do not incentivise local physical collection enough.

“Both are very similar, really, and I am disappointed that we are where we are,” she explained.

Ms Cullis added: “Neither methodology has ever really incentivised physical collections of WEEE. It actually states in the Valpak methodology that Reg 34 requests are similar in Q1 2017 to the same period this year, which shows that even with the big fee, people are using the PBS system. I can’t imagine either will really make a difference in the long run.”


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