Valpak Policy Advisor, Henry Smith provides insights on e-waste regulation reforms. His blog summarises the latest developments which will shape the future of the UK's Waste Electrical and Electronic Equipment (WEEE) Regulations and electronic waste management.
Valpak engaged extensively with members before submitting our responses, but here we will explore some of the key themes of these.
Several proposals within the consultation were ambitious measures to get more WEEE out of residual waste. Chief amongst which was the proposal to introduce a nationwide household collections service for small WEEE. Whilst minimising the amount of WEEE being disposed of via residual waste is a widely supported aim, the lack of evidence that household collections are an effective means of achieving this was plain to see across both the consultation and the associated impact assessment. Given such an undertaking would be a necessarily expensive project to embark on, we believe further research is needed to fully assess efficacy and value for money.
The need for greater information recurred throughout our consultation and call for evidence responses – particularly concerning proposals to overhaul obligations for business-to-business electrical and electronic equipment (EEE) producers, and the introduction of eco-design/eco-modulation measures. Reforms must be evidence-based; therefore, we felt the need to call for greater evidence.
Distributor takeback is a well-established route for WEEE to be recovered and sent for recycling. The consultation expressed a desire of Defra’s to build upon the regulatory provisions underpinning this, expanding the basis on which distributors must take back WEEE, and crucially aligning takeback requirements of online retailers with traditional brick-and-mortar sellers. Valpak has consistently held that obligations for businesses placing items onto the UK market ought to be aligned as far as is practicable, irrespective of their route to market. So, in our consultation response, we supported increasing responsibilities for online sellers, online marketplaces, and fulfilment houses, as well as alterations to the threshold at which retailers become obligated to take back WEEE.
Research shows that notable portions of the UK population are unaware their electricals are recyclable and how to correctly dispose of them. As a result, Valpak supported the proposal that distributors of EEE should have enhanced requirements to inform customers at the point of sale about the many ways in which WEEE can be recycled. We elaborated on our response by urging government to require distributors to provide this vital information through as many avenues as possible. For instance, information about how to dispose of WEEE ought to be printed on receipts for EEE items, as well as making available QR codes linking to recycling information at the point of sale, or even requiring sales staff in-store to tell customers about their rights. To ensure consistency in messaging, we called for any new requirements for in-store retail to also be reflected in requirements online retailers are subjected to.
Vapes have unquestionably presented a challenge to the WEEE compliance system in recent times. Valpak was therefore happy to support efforts by Defra to build upon voluntary actions being taken by us and others to apply the significant cost of managing waste vapes directly and only to their producers through the creation of a fifteenth category for EEE. With the timing of new legislation to install this category being uncertain at present, we’ll continue to act voluntarily and collaboratively across the sector to ensure effective vape waste management systems exist.
Mentions of the timings for implementing many of the measures raised in the consultation were few and far between. This is perhaps of little surprise, not least in light of the experience of implementing EPR endured by the packaging sector across the last five years. Therefore, in our consultation response, we urged government to stage the introduction of various elements of reform to ensure gradual but notable progress in reforming the WEEE system is made, rather than holding reforms back until every aspect is capable of delivery in one sweep of action. For example, the much-needed fifteenth category for vapes, obligations for online marketplaces, and enhanced consumer information requirements must be introduced as early as possible, with larger more operationally focussed reforms such as expanded distributor takeback requirements likely only feasible with a couple of years notice. Further into the future, and only once another round of consultation has been conducted, should larger ticket items such as household collections be considered, to scale up costs and obligations for producers, distributors and other system actors alike.
Throughout our consultation and call for evidence response we aimed to be a constructive partner to government, as much like many other stakeholders across the value chain, we all want to drive up higher standards for the UK’s WEEE system – it is just a matter of determining how best we can achieve it.