But although not much has been said yet about the consultation, one thing seems certain compliance with the WEEE Directive will be via a national clearing house (NCH). And one group of electrical-good manufacturers has outlined its views on how this would work.
The Strategic Electronic Waste Policy Forum (SEWPF) was formed in October 2003 by eight companies in association with the Associate Parliamentary Sustainable Waste Group. The eight electrical firms are Apple, Electrolux, Fujitsu, Hewlett-Packard, Samsung Electronics, Gillette, Sony Computer Entertainment Europe and Sony Corporation.
SEWPFs stated objective is to: Engage decision-makers in the UK Government, its agencies, the devolved administrations and other stakeholders in constructive dialogue with a view to developing and implementing fair and effective solutions to the requirements of the WEEE Directive.
The Governments final consultation paper, released on July 30, said the NCH would be a one-stop shop for producer registration, data reporting and collection. The document asks producers to come up with a working plan for the NCH.
SEWPF held workshops with waste firms, other electronics producers and local authorities, as well as talking to recyclers, compliance schemes, social enterprises and retailers.
Following this consultation, SEWPF concluded that stakeholders needed a NCH to:
l Include devolved administrations in its governance
l Register producers with a limited administrative burden
l Equitably allocate collections to all producers
l Arrange collections for remote areas
l Provide a consistent service to local authority sites
l Promote reuse
SEWPF then released its paper Implementing the WEEE Directive: a national clearing house model to set out how it thought the NCH would work.
The paper says there should just be one NCH covering the UK. It adds: The NCH operator must act according to the specifications in its joint contract with the UK Government and devolved administrations.
While it should be licensed to carry out producer registration, the NCH should not be concerned with upholding the law, according to the paper. Enforcement should be done by the environment agencies. The NCH should inform the agencies of any non-compliance it is aware of.
The paper lists the key functions of the NCH as:
l Registration of producers
l Allocation of collections
l Reporting of collected and recycled volumes
The WEEE Directive insists on producer responsibility. And SEWPF says the NCH should be funded by a registration fee paid annually by each producer placing electronic and electrical equipment on the UK consumer market. The level of the fee will recognise the financial position of small and medium enterprises.
Member states are required to keep a register of electronics producers. SEWPFs paper suggests: The NCH would operate the registry of producers and use the information to calculate producer obligations. Sales data reported to the NCH must be verified by a signed statement from each producers independent financial auditor.
These obligations are naturally a sensitive subject, and the paper says market share should be calculated on the basis of weight. It gives the following three reasons:
l Treatment costs and targets in the WEEE Directive are weight based
l Weight better reflects environmental impact
l Weight-based measurement reduces concerns about commercial confidentiality that could occur from other calculations
SEWPFs solution offers collection sites the opportunity to schedule collections through the NCH either in advance or on demand.
The NCH will allocate the pick-u