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Since the Waste Electrical and Electronic Equipment (WEEE) Directive was introduced in 2007 it has undergone considerable change as more products have been brought within its scope. As with most other environmental legislation, the requirements of the Directive are set to tighten even further, with implications for anyone involved in the specifying, manufacturing or importing of lighting products. Those involved in managing projects that involve disposing of end-of-life lighting products may also be affected.


There are two key areas in which the Directive will bring about change. Firstly, in implementing the Directive, the Environment Agency is set to increase recycling targets by 45% per capita by 2016. This will rise to 65% by 2019.


Secondly, household luminaires are to be included in the scope of the Directive from 2018 - currently, the recycling of household luminaires is on a voluntary basis. This could potentially lead to spiralling costs for manufacturers and importers of these products as they will need to comply and contribute to the cost of environmentally- friendly disposal.


For instance, the current arrangement is that if a compliance scheme records 50% of the total amount of EEE placed on the market, they have to ensure that they are able to provide evidence notes to show that the equivalent WEEE has been recovered. If the targets have not been met they will need to buy evidence notes from other parties at often very inflated cost that reflects a seller’s market.


Therefore, those with the biggest market share will make the largest contribution to disposal at end of life.


2018 will also see switch gear and photovoltaic panels brought into the scope of the Directive.


The underlying reasons for tightening the regulations are that, although we in the UK are doing quite well at recycling luminaires, we’re not doing well enough. Around 98% of all recorded lighting waste is currently recycled through the Lumicom compliance scheme, with a full audit trail. The problem is that much lighting waste is unaccounted for and not recorded. This occurs when waste companies sell the whole luminaire as scrap rather than breaking it down into separate components and recycling the different materials.


For example, when luminaires are disposed of through a specialist compliance scheme the plastic in them is granulated and can be used to manufacture new luminaires or other products. If they are disposed of as general ‘scrap’ the metals will be recovered and recycled but the plastic will simply be sent to landfill – hardly the most environmentally-friendly solution.


In terms of light sources, there are also concerns around unrecorded discharge lamps as these contain mercury and are classified as hazardous waste. Where they end up is unclear but if they were to be disposed of in landfill sites they could wreak considerable environmental damage.


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