FEATURE WASTE MANAGEMENT
WEEE REPORTING shake up on the horizon
equipment with higher weights such as heavy washing machines. Depending on how targets work, this could swing either to give the producer a lower market share within a high reporting category, or expose the producer to a higher recycling target than they would be expecting under the current system. A decision is yet to be made as to whether producers will be required to adopt the new reporting categories or whether another measure will be put in place to capture this information. The problem for many producers, however, is that this is not expected to be finalised until 2017.
In just over two years, companies that produce electrical and electronic equipment (EEE) will have to widen the range of products they report within the scope of the WEEE regulations. James Champ, a senior compliance specialist at ecosurety says we need to start preparing now
A
ny company that manufactures, imports or rebrands EEE will be affected by the changes set out in the WEEE Directive 2012/19/EU, which has been tasked with harmonising reporting and producer responsibility across Europe. Although the Directive has been in
place for two years, the UK is still using the scope of the previous WEEE Directive. However, this will change in 2019, when the UK will be compelled to adopt an ‘open scope’ stance, where everything meeting the Directive’s definition of EEE – apart from items involved in national security, equipment designed to be sent into space, or large-scale, fixed installations – will be determined to be ‘in scope’ of the regulations. Examples of equipment, currently exempt, that would fall into scope from 2019 include household luminaires, such as domestic light fittings and fixtures. To further complicate matters, how the UK will conform with the Directive’s requirement - that EEE data is reported into six categories, rather than the current 14 categories - is a subject of much debate. While the six new categories continue to separate hazardous waste streams, such as
22 SUMMER 2016 | INDUSTRIAL COMPLIANCE
refrigeration, display equipment and lamps, the move to differentiate other EEE as generally either smaller or greater than 50cm2
will inevitably require
producers to re-categorise their products, and there will be winners and losers when it comes to the re- distribution of market share. Producers of equipment which weighs relatively little compared to its size –for example, handheld tools such as vacuums, leaf blowers etc (being more than 50cm) - will be grouped with
Three steps to prepare for WEEE Directive changes
1. Educate yourself on the extent of the changes by engaging with industry forums and get involved with consultations through your producer compliance scheme and information sources such as
www.gov.uk. 2. Review your product lines and assess whether any products will now come under ‘open scoping’ and therefore will require reporting. This may be a large task requiring considerable specialist support to ensure that you are not over or under-estimating. 3. Assess internal reporting systems and map out a timeline of change to ensure you meet the regulatory date of 1 January 2019. Even if you don’t know exactly what’s coming, it’s good to know when things might, to give yourself a chance of meeting the changes head on.
PREPARATION IS KEY Decisions will soon need to be made by producers, or at least considered, to ensure that they are prepared for the changes, despite the current lack of clarification. For many, 2019 is already an unrealistic deadline to implement the amount of change anticipated. Despite this uncertainty, steps do now need to be taken to at least understand the timelines involved internally. WEEE reporting currently involves product management systems overseeing products within the scope of the regulations and relevant reporting categories. As with most IT projects, sufficient lead in is required to map out any changes and to implement them. In group companies, which could use multiple reporting systems concurrently, additional time will need to be factored into any major IT programme re- configuration. Once systems are capable of reporting
in line with the new requirements, there will be a significant amount of re- scoping required to bring databases up to date. Who will be responsible for this? What training requirements are there internally to understand the changes and to categorise products appropriately? All these questions need to be considered. With the decision on reporting categories not expected until 2017, there is still an opportunity to engage with the decision-making process. ecosurety has been working closely with its members on these changes and is delivering a programme of engagement opportunities throughout 2016 to represent their views. We would encourage producers to take similar steps to engage with the legislators in a collective capacity - for example through their trade association - in order to provide more focused, industry feedback.
Ecosurety
www.ecosurety.com T: 0845 0942228
/ INDUST RAL COMPA RI CE
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