March 2024

WEEE Regulations Consultation

Submit your response to the WEEE consultation and Call for Evidence by Thursday 7th March 2024.

You can view the WEEE Regulations consultation documents here.

You can view the Call for Evidence documents here.

As we advised at our recent member meeting, Government’s consultation on reforms to the UK WEEE system includes proposals that could significantly increase the compliance costs your company will incur in the future. These including financing the collection and treatment of WEEE from the household – through the regular collection of small WEEE and an on-demand collection service for all other “bulky” WEEE – the collection of WEEE from retailers that has either been deposited in store or collected on home delivery of a new large appliance, a national consumer awareness campaign and a Scheme Administrator to co-ordinate some of these activities. The additional financial burdens that producers would incur as a consequence of these proposals is illustrated in the diagram below:

Whilst the consultation proposes changes to the WEEE system that will be implemented in the short to medium term, the call for evidence covers some important future policy principles including the potential introduction of eco-modulation within the WEEE system and new obligations for business WEEE.

We provided an assessment of the proposals at our recent scheme member meeting, and circulated the slides presented in REP-ACT-0250. We have concerns over the cost and feasibility of some of the proposals, including the household collection of small and bulky WEEE. Many of our members also advise they do not consider the WEEE Regulations to be the appropriate place to manage the design of products.  Conversely, some of the proposals would deliver a 
real benefit to the UK WEEE system in ensuring a fairer allocation of costs amongst producers; namely the development of a separate reporting category for vapes and the proposed new producer responsibilities for online marketplaces and fulfilment houses.

The number of consultation responses received by Defra counts and we strongly encourage every REPIC scheme member to respond to the consultation and call for evidence where possible. We appreciate that your time is precious, however, this is a one-off opportunity to provide input into a reformed WEEE system that will impact your business in the foreseeable future. You can either prepare your own response, or use the template we sent you in REP-ACT-0252 that has been developed in conjunction with the Joint Trade Associations (JTA). 
If you require further assistance with your response, please contact Janette Ollerhead janetteollerhead@repic.co.uk

 

Government’s proposed WEEE collection targets for 2024 published.

Defra has published their proposed 2024 WEEE collection targets. Thanks to the information provided by our members, detailing market trends in EEE placed on the market and factors that are expected to affect consumer WEEE disposal patterns in 2024, we have valuable insight into potential WEEE arisings and are well placed to provide feedback to Government on the proposed targets.

The table below details the proposed 2024 WEEE collection targets and a comparison to the 2023 targets and WEEE collections:


In summary:

  • The proposed 2024 targets for Large Household Appliances (category 1), Appliances containing Refrigerants (category 12) and Automatic Dispensers (category 10) are equivalent to the WEEE collected in these categories in 2023 and lower than the 2023 WEEE collection targets.
  • The proposed target for Lamps (category 13), whilst lower than the 2023 target, is slightly higher than 2023 WEEE collections. Defra advises this is to incentivise their separate collection in preference to disposal in residual waste.
  • For the small WEEE categories 2 to 9, PV Panels (category 14) and Display Equipment (category 11), the target has increased compared to the 2023 target and actual 2023 WEEE collections. Defra advises the proposed increase in targets for the small WEEE categories is reflective of Defra’s three-year collection trend analysis and their expectations that retailer returns of small WEEE will increase as consumer awareness develops. Whilst for Display Equipment, the higher target is proposed since collections exceeded target in 2023 and treatment facilities are reporting higher than previous volumes in the first quarter of 2024. Defra is particularly interested in receiving input on the proposed PV panel target as they are unsure whether this is achievable.

We are preparing a response to the proposed 2024 targets and will provide a further update on this on Monday 4th March. In the meantime, if you have evidence that you consider would assist with our response, such as factors that may influence the amount of EEE placed on the market in 2024 or the amount of WEEE available for collection, we would be pleased to hear from you – please contact Janette Ollerhead janetteollerhead@repic.co.uk

 

 

EPR disposal fees

We are still waiting for Defra to publish information on estimated EPR disposal fees for 2025. 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 July 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 continue to impress upon Defra the urgency of this cost estimate.

Environment Agency audit of packaging EPR data

The Environment Agency has advised it is aiming to undertake “as many audits as possible” of EPR producers in 2024, with several REPIC packaging scheme members already scheduled for audit in the next few weeks. We will be providing take-away messages from these audits in our April edition of Compliance at a Glance. If you receive notification of an audit, please advise Vikki Law who would be pleased to assist with completion of pre-audit information requested and wherever possible arrange for REPIC representation at the audit to support you with this process.

Packaging Deadlines

EPR H2 2023 packaging data returns

We are completing our EPR H2 2023 packaging data (July to December 2023) that was submitted to us for detailed checking by 15th February 2024. If you opted not to submit your data for detailed checking, the deadline for submission of your completed data form is 28th February 2024. Please compare your H2 data against your H1 data and provide us with a summary of any material changes when you submit your data. This will greatly assist with our reviews.

2023 Packaging Waste Regulation (PWR) data returns

The deadline to submit your 2023 Packaging Waste Regulation data and supporting data files was 28th February 2024, and we are now reviewing your submissions. As this will determine your PRN financing costs for 2024, we will undertake our usual detailed checks.

Please send your EPR and your PWR data to VLaw@repic.co.uk

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