Regulators have moved a step closer to classifying small mixed WEEE (SMW) as hazardous after a final draft version of an Environment Agency (EA) Briefing Note was circulated.
The note requires that where both hazardous and non-hazardous WEEE are collected and moved together, they still qualify as hazardous and must be moved with a hazardous waste consignment note.
Purchasing a consignment note to track the movement of electronic waste is mandatory.
Phil Conran, director at consultancy 360 Environmental told MRW that the EA’s position was not a surprise given that this has been in discussion for some time. The debate was prompted by the potential for hazardous items, such as batteries, to be found in SMW.
Conran said the ruling would add a small level of administration to the waste electronics industry, but as the same rules apply to displays and fridges already, this was “not hugely onerous”.
But he added: “By classifying SMW as hazardous, the question is - are they then going to look at other materials? Then this might actually become more of an issue than it is.”
Conran said the SMW ruling would also affect sites receiving the materials because they must make sure they are certified to receive that classification of waste.
He added that owners of an EA-issued T11 exemption to repair or refurbish WEEE would not be particularly affected by the ruling.
Another document circulated by the EA in December, a ‘Regulatory Position Statement’ also suggests a derogation for SMW, which means collectors do not have to pay for a consignment note for each individual collection. Instead they must pay for just one note on a quarterly basis.
Conran said this ruling “helps and certainly reduces the potential for cost”.
Justin Greenaway, contracts manager for SWEEEP Kuusakoski, said: “The consigning of small mixed WEEE as hazardous waste is the correct course of action as there are undoubtedly hazardous materials in WEEE like nicad batteries, mercury and oils.
“The process of hazardous waste consigning allows the waste flow to be better monitored and theoretically should make it easier for the EA to stop small WEEE from being recycled in a non-compliant manner.
“The re-classification of Pentane fridges as hazardous waste for example doubled the volume of fridges being recycled through UK fridge plants. We can only hope the same outcome is achieved for small WEEE.”
- Last year revised WM2 Guidance on Hazardous Waste was issued by the EA, describing SMW as hazardous, but the EA decided to readjust their position and in December and decided on a dual-classification as hazardous and non-hazardous for the time being.