Presentation to Electrex - Voltimum Birmingham NEC 18 th May 2006

1. Presentation to Electrex - Voltimum Birmingham NEC 18th May 2006

2. Subject/Content • Impact of the WEEE Directive on Recycling of Gas Discharge Lamps • What is the WEEE Directive • What products are in scope • Impact on lamp producers • Recolight Approach • UK Status

3. Introduction • Alex Hawkins – Recolight Ltd • Recolight Ltd – objective is to operate a WEEE Compliance Scheme in respect of Gas Discharge Lamps • Similar approach in other EU countries • Co-ordinated via ELC (European Lamp Companies Federation)

4. What is the WEEE DIRECTIVE ? • Waste Electrical and Electronic Equipment Directive • Legally binding EU directive • Purpose of the directive is to prevent waste or to reduce waste by re-use or recycling • Seeks to improve the environmental performance of all parties involved in the life cycle e.g. producers, distributors, users, consumers etc

5. Which products are covered? Gas Discharge Lamps Filament lamps are excluded e.g. GLS, Halogen • Small household appliances • Large household appliances • IT and telecommunication equipment • Electronic entertainment equipment • Lighting • - Lamps (excluding incandescent and halogen) • - Luminaires (excluding domestic) • - Equipment for controlling and/or spreading of light • Electrical and electronic tools • Toys and sports equipment • Mechanical appliances • Surveillance and control instruments • Automatic distribution equipment

6. Lamps affected by WEEE Directive 100 million gas discharge lamps sold in UK each year Estimate between 15% - 20% currently recycled 80% weight of what is collected must be recovered

7. New requirements for “producers” • Basis of WEEE is producer responsibility for separately collected waste: “Producer is at least responsible for the financing of collection, treatment, recovery and environmentally sound disposal of his products at end-of-life stage” • Definition of Producer: Organisation or person who first puts the product on the market in the UK e.g.: • Manufactures and sells products (Manufacturer) • Resells under his own brand products produced by another manufacturer (own-brander) • Imports products into the UK on a professional basisand first puts them into the market (Importer) • Discharge the obligation Individually or collectively via a Compliance Scheme • Pass on costs only i.e. not-for-profit activity

8. Unique WEEE Issues for Lamp Producers • Recycling cost impact as % of sales price: • TVs, DVDs, White Goods etc: typically 2% - 5% • WEEE Lamps – typically 10% - 80% Critical for all Producers to ensure costs are as low as possible on a sustainable basis to minimise user price increases • Multi-use: WEEE Lamps are used everywhere by everyone! Big quantities!! e.g. estimate = 80% total WEEE by pieces and 1% by weight • Costs to sort into categories e.g. “new vs historic”, “ household vs non-household”, like-for-like vs new or into brands will be huge and on top of the collection and recycling costs Producers need to minimise costs of sorting!

9. Producer Options and Tasks • Do-it-Yourself – example tasks: • Registration details including sales info. • Arrange & manage collection and recycling process • Communicate to and monitor the market to ensure all comply • Gather statistics/keep records/report to Gov’t Manage the process & costs directly, or just pay costs? OR 2. Join a Compliance Scheme, such as Recolight, who will take over Producer’s legal obligations. Producer would then only need to: • Provide registration & sales information to Recolight • Pay their share of costs in the form of a “recycling charge” per lamp

10. Registration Process • Environment Agency = responsible • Independently or via Compliance Scheme • EA will specify the Registration form e.g. • Company details • Type of Products sold • A base year of sales-data (at present this would be 2005) • EA will allocate share of “historic” (up to 2011) • Producers or Schemes have to report their results each year • Registration process: • Starts after legislation issued – legal requirement • Will be to a timetable (to facilitate allocation)

11. Registration via Recolight • Launch an interim Pre-compliance information service: • RAMIS(Recolight Advance Membership Information Service) • Benefits: • Allows Producers to demonstrate their intention to comply • Provides access to more qualitative info • Enables Recolight to plan better • Adds to the Voice of Lamp Producers • “Membership” of the Brand • Lamp Producers only i.e. same criteria as full registration • Will discontinue when full scheme launched

12. Recolight Proposed Compliance Scheme • The Company was founded by GE, OSRAM, Philips and SLI • Set up to manage a WEEE Compliance Scheme and handle the WEEE obligations of all lamp producers who join. • The Scheme itself is open to all Producers on equal conditions and all are encouraged to join • Strictly not-for-profit organisation • Operational plan has to be signed off by Government and be consistent with competition law before operations can start • Actively monitor market for free-riders on behalf of its members to ensure a level playing field

13. Compliance Scheme tasks • Same as Producers with the addition of: • managing the best interests of its members (service and costs) • Setting up & operating the Compliance scheme process • Total costs charged back to members pro-rata to volume • Recycling charge: Total WEEE costs No. of lamps sold x Est Collection %

14. Recolight Approach (keep it simple) Collective system - open to all producers • Sorting lamps by individual brand is very expensive • Historic waste (up to 2011) is a collective responsibiity • Reduction of duplication Support idea of a flat, visible fee - same fee for all lamp types • Flat fee is simple to administer + helps keep costs low • VF gives full cost transparency and understanding by all users Legal Requirement to Register & take responsibility • A simple solution is to join a Compliance Scheme (Recolight or other) • Individual route could be time-consuming/distracting? • A cost effective, non-profit and transparent solution to meet the obligations of the WEEE directive

15. Proposed Collection Process • Cannot be fully defined until legislation finalised • Recolight proposal: • Effective network of Collection Sites – easy access & cost effective • Building on existing trends: • Local Authority sites for Household waste • Dedicated sites where sufficient volume to justify • Commercial Collection points for small-medium businesses • Mutual efficient criteria to control cost impact • Producer responsibility starts with collection from these sites

16. Current UK status • December 05 Government announces review of progress with new Consultation Spring 06 • Publication of Regs to follow – assume Oct 06 • Implementation date = ?? • Already implemented in most EU countries • Ongoing increase in Lamp recycling due to e.g. • Landfill restrictions from July 04 • Hazardous Waste Regs from July 05

17. Summary • Are you a Producer? • Which Compliance route? • How will the WEEE Directive impact your business? • What Can you do now? • RAMIS • Monitoring development of the legislation? • www.recolight.co.uk - gives links to various websites

18. Thank you Thanks for your attention