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Counting the cost

With UK commerce now only months away from the implementation deadline of the Waste Electrical Electronic Equipment (WEEE) Directive, businesses are getting nervous. Jeremy Parsons, managing director of SML Recycling, believes that mandating the take back and recycling of large quantities of virtually any electrical or electronic product means that, for businesses, the potential for complications is immense.

"As with any EU directive, transposition into country-specific law will cause differences of opinion, grey areas and doubtless some confusion," says Parsons. "And although the aims of Government are laudable, responses to the third consultation paper on the WEEE and Restriction of the Use of Hazardous Substances (RoHS) Directives, have clearly demonstrated that there are many areas, such as the specifics of a national clearing house, which need to be worked out."

However, Parsons says that further areas, not specifically addressed in the consultation, also need to be clarified to give businesses greater choice in terms of their end-of-life goods. In fact, this choice could ensure that a monopoly on levies is not caused, subsequently saving UK plc significantly.

"The levy - of an additional 1-2% of a product's value at purchase - paid by businesses will account for the recycling or disposal of that product at its end of life and will be introduced at the time of purchase of electrical and electronic products. While there is little argument against a levy to be borne by the business user, the issues occur in relation to how that levy, or cost, should be structured - and when it should be applied."

Parsons says that for consumers the up-front levy makes sense as charging at purchase means the 'catch' can be made quite efficiently, but for businesses, such a solution is not necessarily the right choice.

"Firstly, the recycling or disposal of a product may not happen for five years or more, resulting in the business customer paying for a service that will not be required for a significant amount of time - creating a fundamental issue for UK plc in terms of cash flow," he says.

"We believe that while companies must accept the obligation to recycle, they should have the ability to opt out, if need be, of paying the levy at the point of initial purchase. Getting rid of waste is a business service that companies should be able to purchase in the marketplace, by shopping around."

Parsons believes that with the proposal as it stands, producers could end up with an effective monopoly on recycling, as the levy of 1-2% is hidden and compulsory. However, he says that manufacturers do not want a monopoly and are willing to accede some control of this area to willing recyclers. By not making the levy transparent, a competitive market forming in the usual manner would be prevented.

He says that it is not only a question of the business user being able to have a choice. If a company seeks to work with an outsourced contractor to seek value recovery from products, fewer goods will go for recycling and more will be pushed down the remanufacture route.

"Companies need to know that at the end of a product's life, equipment with data on it will be handled in a responsible manner. It is entirely reasonable therefore for a business customer to want to handle disposal himself. Although there is a link to this in the third consultation that says that producers can make alternative arrangements with business users, such alternative arrangements will only be available to the broad business market if explicitly suppo

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