A National Clearing House (NCH) was proposed by producers of WEEE as an administrative body to assist in the regulation of producers and the allocation of WEEE to producers (who could also be represented by compliance schemes). The clearing house concept then won some support from the Department of Trade and Industry which included the idea in its consultation paper, issued in July on implementation of the WEEE directive.
Consultations were due in at the end of October and in its response, Transform – a collaboration between Biffa and European Metal Recycling – said that while it supports the development of a national clearing house it is concerned that the responsibilities of the NCH had been underestimated.
The response states: “We would urge the government to not underestimate the range of responsibilities that producers will expect the NCH to be able to satisfy and believe this extends beyond the specification suggested in the consultation.”
Transform compares the role of the NCH to that of the agencies in the packaging waste regulations. Roles that Transform believe should be covered by the NCH include: provision of technical expertise to producers on definitions, categorisation and scope, physical monitoring of Designated Collection Facilities (DCF) and Authorised Treatment Facilities (ATF), quality control on compliance schemes and evolvement of the regulations.
Allocation
The organisation has also backed an option to allocate WEEE by site. The consultation offers three options for the allocation of WEEE by the NCH, allocation by individual container, allocation by a series of container pick-ups and allocation by site.
The option Transform believes the latter option to be most suitable with WEEE arising at a particular DCF being allocated to a producer or compliance scheme for a set period of time with an agent allocated to collect the WEEE from that site.
In its response Transform states: “This option offers the best opportunity for best practice and the continuity of supply that will be expected by haulage and treatment contractors.”
But it has warned that there is a risk of continuous re-allocation of sites as the NCH strives for “geographical equity”. Transform believes that for this system to work one of the key aims of the NCH must be to ensure that sites are not passed around compliance schemes continually.
Timetable
Another of Transforms fears is the current timetable for the WEEE Directive. The government intends that allocations for the collection sites begin on August 13 2005, the day after the registration for producers and retailers closes.
Transform said: “The consultation proposes that registration of the producers and collection sites should take place up to August 12 2005 and that more than 1,000 collection sites should then be allocated and start being serviced the day after.
“This would mean that prior to August 13 all the DCFs would need to be permitted by the agencies and developed to meet the WEEE separation requirements. This is simply not going to happen, let alone the NCH be in a position to apply a fair and equitable allocation on August 13 and let alone producers or their schemes being in a position to then set up collection and supply contracts.”
Transform believes that producer responsibility should be held until the beginning of November 2005, giving all organisations involved at least two months to make proper arrangements following the registration deadline.
Data reporting
There are concerns raised over the reporting of business data to the NCH and on whom the responsibility should fall for this. Transform believe that this should be up to the ATF as the final line in the WEEE chain.
The report states: “We believe rather than having potentially, a million businesses reporting on WEEE disposal, Authorised Treatment Facilities should have the reporting of all business WEEE received, a condition of accreditation.”
- The next step for the government will be to publish the responses at the end of the month. The DTI hopes to put the regulations to government by January at the latest with late December a preferred date.
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