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April 2024

WEEE Consultation –
Next Steps

Defra’s analysis of the WEEE consultation responses and confirmed timelines

Thank you to all our members who responded to the WEEE Consultation or provided evidence to contribute to REPIC’s consultation response. Defra is now reviewing the responses and considering how to take the proposed policies forward, in addition to determining any further development work that is necessary on the topics included in the call for evidence.

At the recent WEEE Conference Defra provided the following analysis of consultation respondents:

 

Defra is aiming to issue the Government’s response within three months of the consultation closing. Alongside the JTA we will be considering where we want to undertake further work on the proposed policy areas, such as gathering more evidence or developing alternative proposals.

 

WEEE Collection targets for 2024 revealed

Defra has announced the 2024 WEEE collection targets, which have increased in most categories compared to the provisional targets issued for comment. The final targets are shown below, compared to 2023 reported WEEE collections, the provisional 2024 target published by Defra and the 2024 target assumption we used to estimate your company’s 2024 WEEE financing obligation in November 2023:

Some of the increases compared to the provisional targets reflect the final 2023 WEEE collections figures rather than a change in approach – Defra is still applying a 0% increase for the LHA and Cooling categories, and a small (0.3%) increase for the GDL category. A higher percentage increase has been applied to the Small Mixed WEEE, category 2 to 10, targets (from 3.6% to 4.6%) and Display (from 5.2% to 7.6%). Defra explains this is due to an expectation that Small Mixed WEEE collections will rise due to the ongoing consumer communications and takeback schemes, and that treatment facilities are reporting that Display collections at the end of 2023 and in early 2024 have increased. The PV Panel target has reduced slightly compared to the provisional target.

Once the Environment Agency has issued the final 2023 UK EEE and WEEE data we will be updating your company’s 2024 invoicing, and will issue revised 2024 cost estimates in May.

 

Everything you need to know about Phase 7 of the DTS

As we advised in REP-INF-0201, Phase 7 of the Distributor Take-back Scheme (DTS) has opened. This allows some distributors selling electrical and electronic equipment (EEE) directly to household end-users to opt out of their take-back obligations. Distributors that are eligible to join the DTS instead of providing take-back, can pay a fee which is used to support Local Authority household Waste Electrical and Electronic Equipment (WEEE) collection projects. Phase 7 of the DTS runs from 1st January 2024 to 31st December 2026.

As general Government policy is that distributors should provide systems by which householders can return their WEEE in most circumstances, Phase 7 of the DTS is only open to those distributors selling EEE directly to household end users that:

  • Supply EEE online only; or
  • Sell less than £100,000 of EEE per year.

In-store take-back of WEEE is required for those distributors selling vapes, irrespective of whether they sell less than £100, 000 per year, however, this does not preclude distributors of vapes below this threshold from joining the DTS for any other types of EEE which they supply to household end-users.

If you were a member of Phase 6 of the DTS you will need to register for Phase 7 unless your company no longer sells EEE directly to the household end-user.

For further information regarding Distributor obligations please go to: https://www.gov.uk/electricalwaste-producer-supplier-responsibilities or contact janetteollerhead@repic.co.uk 

 

Navigating the changes in EPR for Packaging Waste

EPR disposal fees

We are still waiting for Defra to publish information on estimated EPR disposal fees for 2025, which we understand they are still “awaiting clearance” to issue. These are the fees that will be payable to reimburse local authorities for your company’s share of the costs they incur in providing a household packaging waste collection and disposal service. Defra advises the first fees will be payable in 2025 based on the packaging your company places on the market in 2024.

Production of this cost estimate has been made more difficult by the impact of the delay Defra granted on EPR data submissions last year, which means they only have a partial POM dataset from which to calculate this. We expect that the change in definition of household packaging, which we outlined in our March 2024 newsletter, will also impact the accuracy of this cost estimate as producers will not be required to report under the new definition until 1st October 2024.  We continue to impress upon Defra the urgency of this cost estimate and the importance of its accuracy.

Environment Agency audit of packaging EPR producer data

As we explained in our March 2024 newsletter, the Environment Agency is aiming to undertake “as many audits as possible” of EPR producers in 2024. Our top three take-aways from the audits we have attended to date are below.

  1. Report all items of packaging, even if they are very minor
    Whilst having robust data for the largest items of packaging or those you supply in the biggest volume will have the greatest impact on your obligation, an audit priority appears to be ensuring all items of packaging, however, small are reported. As examples, you should ensure your data includes any labels, tape, staples, rubber bands, glue and silica gel.
  2. Accurate data for every packaging item, including shipment and transit packaging is required
    Whilst collection of robust shipment packaging and transit packaging weight data can be challenging for producers using overseas distribution hubs in particular, accurate data is essential. This is particularly important for household shipment packaging, since UK producers will collectively share the costs of household packaging collected for recycling by Local Authorities once Disposal Fees are introduced in 2024.
  3. Quality Assurance of weight data provided by suppliers, including your own overseas factories is expected and you should use calibrated scales to do this
    It is expected that you will check that any weight data provided by third parties, including your own factories, is correct and use calibrated scales to do this. Whilst this does not require you to check the weight of packaging around every product, you should have a Quality Assurance programme that will allow you to verify if data is robust. This should enable you to identify and resolve discrepancies relating to for example, specific factories or suppliers. Sample weighing to check the weights reported are accurate is typically undertaken by the Environment Agency at audit.

Whilst these are our top three take-away points that will be relevant to most REPIC members, in addition, exclusion of any packaging that is not reportable under EPR for example, packaging that is exported and second-hand UK packaging such as pallets has also been a feature of Environment Agency audits. All packaging producers should also have a documented methodology detailing how you collect and collate your EPR data.

If you receive notification of audit, please advise Vikki Law at vlaw@repic.co.uk  to assist with completion of pre-audit information and to arrange REPIC representation at the audit to support you with this process.

2024 member visits

We will be commencing our packaging scheme member visits for 2024 shortly. Our focus will be on scheme members that are either due a REPIC Packaging audit, or which we did not visit in 2023. As part of the process, we will undertake sample weighing and a site walkaround to help you ensure that you have captured all of your reportable packaging.

 

Update on the latest developments on Packaging EPR – Join us

In addition to providing a general update on Packaging EPR, including the new definition of household packaging, we will cover some of the common data issues that we have identified with H2 2023 reporting at our REPIC Packaging EPR ROOM on Friday 17 th May 2024 at 10:00-11:30am. We hope you can join us.

If you haven’t already done so, please contact janetteollerhead@repic.co.uk to book your place.

 

Quarter 1 EEE and Battery POM data deadline is 21st April 2024

Please report your 2024 Quarter 1 EEE and Battery POM data to us no later than 21st April 2024.

As this is the first quarter of the compliance year it is a good time to undertake a review of your reporting to check that:

  • All EEE products are captured by your reports and allocated to the correct EEE categories.
    • For example any product containing refrigerants such as condenser tumble dryers or air conditioning units should be reported in Category 12, microwaves should be reported in Category 1.
  • Product weights are up to date and exclude the weight of any batteries and packaging.

If you have any questions relating to your EEE or battery placed on the market data, please contact janetteollerhead@repic.co.uk

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