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Waste Matters Regulation, Opportunities & Achievements. WEEE – A short post-implementation review Mark Hadley. Original Aims. WEEE Directive introduced into UK law in January 2007. Aim - reduce the amount of EEE being produced and to encourage everyone to reuse, recycle & recover it.

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waste matters regulation opportunities achievements

Waste MattersRegulation, Opportunities & Achievements


A short post-implementation review

Mark Hadley

original aims
Original Aims
  • WEEE Directive introduced into UK law in January 2007.
  • Aim - reduce the amount of EEE being produced and to encourage everyone to reuse, recycle & recover it.
  • Aim - to improve the environmental performance of businesses that manufacture, supply, use, recycle and recover EEE.
why have a weee directive
Reduce the overall amount of WEEE being deposited in landfill (5-8% year on year increases in EU).

Create a separate WEEE waste stream, ensuring it’s processed, accounted for & reported.

Fastest growing EU waste-stream 2005.

Why have a WEEE Directive?
why not have a weee directive
Why not have a WEEE Directive !
  • Essential counterpart to RoHS Directive for

Pb, Hg, Cd, Cr,


  • Municipal Collection costs for WEEE pass to PCS & therefore to producers/consumers
chronology of weee
Chronology of WEEE
  • Feb 2003 > EU Directive 2002/96/EC Issued.
  • Aug 2004 > WEEE Directive Implementation Date
  • Jan 2007 > WEEE (Amendment) Regs. SI 2007:3454 passed into law in UK
  • July 2007 > UK Household & Comm. Producers in PCS
  • Jan 2008 > EC compliant in all Member States
  • Dec 2008 > EC proposes revision of WEEE Directive
  • Jan 2010 > WEEE (Amendment) Regs. SI 2009:2957
  • Jan 2012 > Proposal debated by Euro Parliament for a

Re-cast WEEE Directive.

where s the missing weee
Where’s the missing WEEE?
  • Non-obligated WEEE not counted (scrapyards).
  • Cannot separate small items from general domestic waste
  • Illegal export of WEEE
  • No match up between historic rates of EEE placed on market
  • Appliance lifetime issue
  • Appliance weight reduction
problems at inception lateness
Problems at Inception - Lateness
  • Directive adopted in 2003, but EU compliant only by Jan 2008.
  • In the UK, there were three separate consultations, delaying commercial preparedness.
  • Costs of establishing PCS system increased by delays.
  • Late implementation of the EA Settlement Centre (Clearing House).
problems at inception complexity
Problems at Inception - Complexity
  • Although Directive only has 19 Articles, implementation left to Member States many of which had operating systems already.
  • Exclusions – EEE installed in trains, planes & automobiles outside Directive.
  • Integral Parts – large stationary tools excluded
  • Some wastes fell within scope of already implemented waste legislation (ELV), or

impending legislation (Batteries Directive) 2010

mechanisms for compliance
Mechanisms for Compliance
  • Actual compliance varies across Member States, two aspects:

>Joining a PCS (mandatory in UK

but optional in most EU)

>Registration with the Government

usually done by PCS, but in 11

countries, it’s a separate process.

  • Imagine you are a Producer manufacturing/placing product in all 27 Member States!
2007 2010 the first 3 years
2007 – 2010 The first 3 years
  • Day 1, WEEE Day (01.07.2007*)
  • The new PCS market.
  • Double counting, the problem with ‘Evidence Notes’
  • Public awareness
  • Intentional over/under collection

*Household Waste Collections.

day 1 weee day 01 07 2007
Day 1, ‘WEEE Day’ (01.07.2007*)
  • Substantial number of PCS’s did not have signed contracts with Local Authorities.
  • Service collections have to start immediately, or old collections continue.
  • Capex involved in scaling up for contracts by recyclers, training and operational demands.
the new pcs market
The New PCS Market
  • 37 PCS are approved by Environment Agency & SEPA, which one should producers join that is most appropriate for them?
  • All EU Member States have one or more national schemes, but all are fee paying.
  • Most PCS operate in one country, but a few are EU wide (ERP and RENE).
  • Most countries have a couple, only Germany and UK multiple PCS’s and Holland where the scheme was based on WEEE categories!
double counting
Double Counting
  • Once obligated WEEE arrives at the DCF it awaits collection by appointed collector for PCS.
  • Evidence notes only issued on treatment, recovery or recycling or WEEE at the AATF.
  • However, some WEEE passed to a AATF, then on to a ‘final’ processor resulting in double counting of the tonnages.
public awareness
Public Awareness
  • April 2005 launch of the RSA ‘WEEE Man’ premature.
  • Initial launch at County Hall, syndicated to 400 TV stations worldwide.
  • Moved to Bristol Docks with seminars and RSA WEEE Man website & schools programme.
  • Permanently housed now at Tim Smit’s Eden Project.
public awareness1
Public Awareness
  • 2009 survey, ERP found that 84% of respondents cited public awareness a major problem.
  • WRAP awareness campaign Dec 2008 (18 months after WEEE) not very successful.
  • Following selective local authority campaigns using radio and TV, collections increased by 30% (London Remade).
intentional over under collection weee
Intentional over/under collection WEEE
  • PCS required to balance producer obligation/collection tonnage.
  • Producer group supported PCS’s such as Repic failed to get DCF tonnages required, whilst waste management-derived PCS’s got the tonnages, but few producers.
  • Judicial review 2009 confirms over-collection unlawful, leading to PCS’s encouraged to agree mutual balancing arrangements in advance.
2010 amended the weee regulations
2010 Amended the WEEE Regulations
  • Streamlining of evidence process – AATF’s and AE’s issue evidence of WEEE received, rather than WEEE treated, thus reducing double counting.
  • Approved PCS no longer have to apply every 3 years for approval.
  • New PCS approvals are now ‘open-ended’ based on operational rolling plan each year. No approved plan = no approval.
the recast weee directive
The RECAST WEEE Directive
  • In Dec 2008 EC proposes revised Directive.
  • Will involve clarification of producer responsibilities
  • Give consumers positive involvement in ensuring more EEE goes to collection facilities
  • Will count in WEEE from all stakeholders, rather than just PCS route, impeding illegal exports
  • Will set new ambitious collection targets, possibly doubling amount currently reported as collected. (Current target 4Kg per europerson)
it equipment a case study
IT Equipment – A Case Study
  • There are 10 categories of WEEE
  • Cat 3, IT & Telecommunications equipment.
  • In 2010, 206k tonnes placed on market but only 35k tonnes collected by PCS.
  • Much of the missing waste went direct to processors from the businesses themselves or specialised collectors due to value.
and finally
…and finally
  • Producers were charged between £40-£50m for 2010 compliance period.
  • Under UK Regulations producers not charged actual cost of recycling.
  • Prices agreed between PCS and WM companies acting behalf of LA’s.
  • Hidden & complex price setting means recycling costs have fallen, due to rise in value of commodities
  • WEEE estimated to have a overall net value in 2010!