Ann Summers, the UK’s leading erotic and lingerie brand, has become a high street success in recent years, with 138 stores across the UK and Republic of Ireland, plus a thriving online retail business.
The company was one of the first to sign up to WEEE Ireland, which is administered through the WEEE Register Society. The latter’s principal function is to register and monitor waste electrical and electronic equipment (WEEE) and battery producers in the country.
However, the retailer did not appreciate from the outset the in-house expertise required to oversee the collation and submission of monthly compliance data for WEEE waste in Ireland, which takes place via an online reporting platform.
As a result, its data records remained incomplete, which led to difficulties in 2014 when the company was asked by the Environmental Protection Agency (EPA) in Ireland, the regulator for producer responsibility, to prove its historic WEEE and batteries obligations.
The company turned to Ecosurety for help in its Irish operations. The two had been working together since 2007 to deal with its WEEE obligations in England, Scotland and Northern Ireland, which led Ann Summers to subsequently ask it to deal with its UK packaging and battery compliance obligations.
The first thing Ecosurety did was to ensure that WEEE waste was collected by a certified collector, the data accurately captured and the waste properly offset against the company’s obligations.
It also acted as a communications bridge between Ann Summers and the EPA during six weeks of intense negotiations, to ensure that historic data was properly benchmarked and submitted. Discussions took place over the telephone but also, crucially, face-to-face in order to be able to reach agreement.
To ensure figures would be acceptable to the EPA, Ecosurety devised a bespoke obligation methodology that took into account changing product lines over the decade since registration, which had previously made the backdating of obligations almost impossible. The company also set up a series of rolling monthly compliance targets to enable Ann Summers to submit annual obligations.
Ecosurety’s actions ensured that the company avoided any prosecution for noncompliance, despite negotiations continuing beyond the EPA’s deadline.
From the start, Ecosurety’s role was to fight Ann Summers’ corner, and find agreement on obligations stretching as far back as 2005 so that they could be registered and taken into account. Ecosurety was also on hand to provide advice and support on a range of waste compliance matters for the company, so that it could concentrate on its day-to-day business operations.
Despite the difficult negotiations and the need to adopt a pragmatic approach towards the data, Ecosurety never lost sight of the fact that the goal was to ensure Ann Summers became wholly compliant and was reporting as accurately and as reasonably as possible.
Since it began working with Ecosurety, Ann Summers has become compliant across all three areas of its waste obligations in both the UK and Irish Republic. Its battery, WEEE and packaging submissions have increased every year since 2008, while its WEEE waste has more than halved, from 224 tonnes in 2009 to 84.4 tonnes in 2014.
Ecosurety also visits the company’s main warehouse at Paddock Wood, Kent, once a year to weigh systematically the packaging of its most important products that season. This is to ensure the packaging data remains as accurate as possible, despite frequent changes in product ranges.
With the sale of battery products also climbing, Ecosurety plans to start weighing batteries to further improve the accuracy of those compliance figures and ensure the company hits its 40% battery recycling target for 2015.
Top tips for producers
1 Register before the regulatory deadlines for each year or within 28 days of becoming a producer for the first time.
2 Keep a regular track of the electrical/electronic products and batteries placed on to the market and packaging weights. Spot-check top-selling products, especially seasonal lines, so that the figures accurately represent sales cycles.
3 Do not wait for the knock at the door from the regulator. The process can be extremely gruelling and resource-intensive, requiring staff to go through historic records as well as attend meetings.
Investing in a compliance specialist to oversee your obligations might be the best use of your company’s time, particularly if your organisation does not have the internal expertise to manage waste collections, reporting and accounting across the three different regimes for batteries, WEEE and packaging.
Robbie Staniforth is relationship team manager at Ecosurety