Replies to the government's latest consultation said that it was a risk to rush through complex regulations in a short timescale and the time given for designated collection facilities (DCFs) to be upgraded to accept WEEE was insufficient.
The concerns were raised third and final consultation for the WEEE Directive which closed on October 29 2004 with responses published by Defra yesterday. As well as doubts over the timing of legislation there were strong calls for a National Clearing House (NCH) and suggestions as to how much input producers should have into collection services.
Clearing House
One of the main areas that was discussed in the consultation responses was a proposed National Clearing House to oversee the registration of producers and the allocation of responsibility of WEEE. About 96% of stakeholders supported the proposals for the NCH.
However, many reservations about the NCH still remain. Some of the respondents stated that there should only be one NCH in the UK in order to keep the system simple. The idea of a small advisory for the NCH was considered by many to be inadequate. There were also calls for the costs of the NCH to be made transparent.
The general feeling of stakeholders was that the clearing house should not be involved with any areas of WEEE other than registration and allocation. The consensus was there could be a “conflict of interests” should the organisation that runs the NCH also be involved elsewhere in the WEEE process.
Collection sites
Concerns were expressed by prospective operators of DCFs that managing the extra collections involving WEEE could provide problems due to a lack of space at designated sites.
There still remain question marks over how the upgrading of CA sites will be funded. Several collection site operators expressed concern over potential increases in costs due to extra training and health and safety issues. A small number of the responses also claimed that the geographical spread of the collection sites may at present be inadequate.
In the consultation the government had asked how much involvement producers should have at the collection facilities. Almost half the respondents believed that the producers should have no involvement at the sites themselves.
Those that supported some involvement of producers gave varied opinions on the overall contact levels. Some believed that regular site visits were the way forward while several believed that a very low level of contact was required, such as occasional telephone calls. Most agreed that if re-use is to be managed successfully then some involvement by the producer will be necessary.
Allocation
The government offered three options for the allocation of WEEE to producers' responsibilities. These were collection by individual container, collection by a series of container pick ups and collection by site.
Most of the responses preferred the allocation by a series of container pick-ups. A total of 75% of the responses and 85% of the responses coming from small businesses supported this option.
Several stakeholders warned that if allocation was designated by a series of container pick ups and certain sites received consistently low quality WEEE, some collectors may refuse to visit the poor sites.
Alternative arrangements
The government has suggested that producers be given the opportunity to fulfil their obligations by means of a different route. The two options offered were a direct point-of-sale collection agreement where producers make their own arrangements with retailers and a local agreement with collection sites. This second option would allow a collection site owner to make a long-term arrangement with a community recycler. This suggestion received a great deal of support although neither of the two options was seen as a clear way forward.
The government has categorised WEEE for the purpose of collection and in the consultation asked whether respondents agreed with its categories. Many disagreed with the proposed categories but almost all of the responses felt that there was a need to categorise the WEEE.
There was a request from several organisations that an active pursuit of free-riders should occur. Many of these responses also claimed that this pursuit should be funded by fines and prosecutions.
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