5 April 2018

WEEE subsistence fee: a letter from WEEE Light

The increased subsistence fee charges the Environment Agency announced last month has caused some debate in the WEEE sector, with Vince Eckerman, director of compliance scheme WEEE Light, writing about his concerns to the Environment Agency and letsrecycle.com (see below).

Vince Eckerman wrote a letter to the Environment Agency and letsrecycle.com

The background to Mr Eckerman’s concerns are that on Thursday, March 21 2018, the Environment Agency unveiled a new charging scheme for regulatory permits and services which it said would ensure businesses cover the costs of services rather than the public (see letsrecycle.com story).

Among the announcements, some annual WEEE charges which the EA levies on producers would more than triple from 1 January 2019, the start of the next compliance period.

Subsistence

Current Agency subsistence fees, which cover the policing of WEEE, were £210 for companies with a turnover below £1m, and £445 for companies with a turnover above £1m.  The EA announcement waste to increase both these charges to £750 from January 2019.

This was criticised by the Recolight WEEE compliance scheme chief executive, Nigel Harvey (see letsrecycle.com story).

Mr Harvey said then: “It is disappointing that the EA did not take on board comments made during the consultation process.  This increase will be particularly difficult for small and medium sized companies. The EA were presented with alternative, fully costed funding options that would have limited the impact on businesses with a turnover below £1m.  These alternatives would have spread the increase more fairly across the range of operators in the WEEE system.  However, they were ignored, in favour of this excessively costly solution.”

Now, Mr Eckerman, who is director of WEEE Light Ltd, has raised his concerns in the letter below. WEEE Light Ltd’s parent company is AVC Weeeco which describes itself as the delivery partner for WEEE Light Ltd and also for Northern Compliance Ltd.


LETTER TO THE EDITOR

In a letter in response to the letsrecycle.com article on 26 March (Environment Agency under fire over WEEE charges), Mr Eckerman, has written the following:
Sir,

We write in response to your article on 26 March where you report Recolight and Ecosurety criticism of the decision by the Environment Agency on 21 March to increase the subsistence fee charges for UK producers and the introduction of a new subsistence FEE for PCS.

WEEE Light Ltd raised serious concerns to the WEEE Schemes Forum (WSF), EA and DEFRA prior to the deadline for submission of responses, which resulted in 11 other schemes agreeing that, the WSF submission was flawed. Despite this the WSF solution was submitted referencing that 11 opposed the response to EA. (Interestingly the respondents on behalf of Recolight and Ecosurety in your article are amongst the authors of the WSF submission).

I informed the WSF, EA and DEFRA (during the last WSF meeting 7 February) of WEEE Light’s disappointment that the WSF’s response would miss the opportunity create a structure which was fair to all UK businesses. It is ridiculous to image that a company with an £3bn turnover associated to placing EEE in the UK would have a problem with paying the new subsistence fee of £750. In contrast a company with a £1m turnover with only £30K of this income associated to placing EEE in the UK will have to pay the same amount as its £3bn turnover competitor. Furthermore the introduction of a flat FEE for PCS without regard to its size or indeed its WEEE obligations creates exactly the same injustice as that we see for Producers.

WEEE Light Ltd fully appreciates the challenges the EA have in policing EEE and WEEE compliance in the UK and the articles’ comments by Ecosurety seemingly confuse the costs of recycling with the EA’s costs of policing the UK WEEE Regulations. A fair solution, which was submitted as part of our response to the consultation, is a mechanism linked to 1) a companies EEE placed, 2) a PCS’s WEEE obligations and, 3) an AATF’s WEEE Collection Volumes.

We believe the EA needs to go back to its drawing board and consider the key factors especially given that the mechanism for producer subsistence has always been unfair.

 Key facts:

  • Polluters pay in the UK via producers and their schemes in an open marketplace
  • Today there is no government narrative that objects to the number of producers, PCS and/or AATF
  • The UK systems only true common denominator is a producers EEE placed weight by category which is exercised through a PCS scheme obligation and collected by AATFs
  • Fixed agency fees for Producers calculated against turnover is clearly not a fair; nor indeed a sustainable charging mechanism for smaller producers
  • Fixed agency fees as a one charge fits all for PCS is clearly not fair; nor indeed a sustainable charging mechanism for smaller PCS
  • The real opportunity missed by the EA in the consultation process was to recover the funds required by the agency to police a compliant system in the UK in a fair, balanced and level playing field for all. We suggest a starting point for re-consideration would be:
    a. 
    Producers pay per tonne of EEE Placed against the budget set by the agency = level playing field for all
    b.  PCS  pay per tonne of EEE Obligation against the budget set by the agency = level playing field for all.
    c.  AATF pay per tonne reported against the budget set by the agency = level playing field for all

We look forward to hearing back from all stakeholders if we are totally off the mark here however,  We hope any arguments against our proposal for a re-think would be strong enough to explain why:

  • a producer placing significantly less EEE subsidises producers placing more
  • PCS with significantly less EEE obligation subsidises the PCS’s with more obligation
  • an AATF collecting significantly less volume subsidises AATF’s collecting more volume

Yours faithfully

Vincent  F Eckerman

Director, WEEE Light Ltd

[Mr Eckerman also wrote a similar open letter to the Environment Agency, which can be found here.]

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