Amidst concerns that the UK could miss recycling targets for waste electrical equipment this year, operators of treatment plants have warned that the way regulators classify WEEE is a factor behind any shortfall.
The plant operators reason that the lower than expected recycling rates in 2017 – for waste electrical and electronic equipment (WEEE) – are largely a result of differences in the way the waste equipment is being defined and recorded by regulators and also because of illegal exports. This approach contrasts to a view held by some producer compliance schemes that the reduced amounts of new products being bought – and in turn reduced volumes of old products going as WEEE – is the reason for the lower recycling rates so far in 2017.
Consequently, the operators are calling for “challenging targets” in 2018 to pull more WEEE properly the recycling process rather than any softening of targets because of a perceived reduction in arisings due to less new goods being put on the market.
The warning from the plant operators comes via the recently formed trade body, the AATF Forum. AATF stands for ‘Approved Authorised Treatment Facilities’ and these are the sites which process waste electrical equipment ranging from televisions to lighting and cooling equipment. The Forum has 18 members accounting for an estimated 90% of the UK’s AATF capacity.
Data available for the first nine months of 2017 prompted the producer compliance schemes in the WEEE sector earlier in December to caution that targets for recycling this year might be missed (see letsrecycle.com story). And, the compliance schemes called for more detailed analysis of data covering the volume of electrical goods being placed onto the market, in order to inform future target levels for WEEE collections.
Now the Forum suggests that the compliance schemes are putting too much emphasis on the relationship between new and old equipment as a potential reason for the UK failing to meet the targets. The Forum says that the data “is being mis- represented to suggest that the falling levels of collection are due to a reduction in the amount of EEE placed on the market”.
While the Forum accepts that there is some volatility in the amount of EEE placed on the market and WEEE collected, using two charts it argues that the decline in the weight of collections “is significantly greater than the decline in EEE placed on the market”.
It then looks at other factors which could be behind this greater decline in amount of WEEE being collected.
The Forum says that the reduction is collection is more because of leakage from the regulated WEEE system than a reduction in actual volumes becoming available for recycling.
And, it suggests there are two areas where WEEE is “leaking” from the system:
- The growth in unrecorded reuse. Significant quantities of used appliances and displays, especially from retailer collections and warranty returns, are now being treated for reuse without being classified as waste. There appears to be wide differences in the definition of waste across the UK with the position of the Scottish Environment Protection Agency, for instance, being that all used EEE should be classed as waste from the point of collection whereas the Environment Agency indicate that assessment can be made once the used EEE arrives at an AATF.
- Illegal exports and unreported treatment. AATF Forum members have reportedly seen a recent increase in enquiries from ‘dubious’ businesses seeking to purchase any usable items for export regardless of the condition and it is clear that WEEE from other sources such as car-boot sales and online platforms is also being illegally exported.
In addition, the Forum says that some WEEE may be going as scrap without being recorded and that there also large volumes of ‘unobligated’ WEEE being reported by some AATFs. And, there are clearly still significant quantities of WEEE entering ATFs and being processed as scrap.
While producer compliance schemes have been set recycling targets and they can ‘buy’ evidence if they fail to meet their targets, Defra can also add in estimates for WEEE which is not covered by the compliance schemes. This could, for example, cover products which have been sent for reuse and not counted as WEEE – this approach is known as using ‘substantiated estimates’.
However, Defra needs to be able to validate the estimates and so the Forum is suggesting that “proactive measures” are need to close the gap between current collection levels, which it estimates at 40%, which are considerably below the 65% EU collection target for 2019.
The Forum is chaired by independent consultant, Phil Conran of 360 Environmental.