The waste industry is no stranger to regulation and is certainly accustomed to the goalposts changing on a regular basis.
But one recent change is causing considerable concern for the producers of LED light sources and, potentially, creates a need for the waste disposal industry to take a more active role in educating its customers.
LED lighting technology is a relatively new entrant to the lighting sector but is making major inroads so that volumes being placed on the market are growing rapidly.
However, a recent change to the classification of lighting waste has led to LED retrofit products being included in WEEE Category 13, which previously only applied to ‘gas discharge’ lamps (fluorescent, sodium, metal halide). The critical issue here is that gas discharge lamps are classified as hazardous waste and are therefore subject to higher disposal costs than non-hazardous waste such as LED lamps.
When LEDs were recast into Category 13 it was deemed that they would not be treated as hazardous waste and therefore their disposal would not need to be more costly. But experience has shown that this is not the case and LED producers have seen a significant increase in their costs. The situation is exacerbated by the fact that such businesses often pay for the disposal of their products when they are put on the market rather than when they reach end-of- life. Because of the long life of LEDs, this means that disposal payments are being made many years before the products are disposed of.
The problem is that it is difficult for a consumer to differentiate between the types of light source. It may even not be obvious to an electrical contractor or a lighting designer, but general contractors and householders are unlikely to have the requisite product knowledge.
The result is that LEDs tend to be disposed of with hazardous waste such as discharge lamps, so that the whole load becomes contaminated and needs to be treated as hazardous. Even at council collection points, where different bins may be available, there is still a reliance on the consumer knowing the difference between products. Illustrated signage certainly helps but is not fool-proof because many LED lamps are designed to look like traditional lamps.
One solution may be to identify different products through labelling, but better education across both the business-to-consumer (B2C) and business-to-business (B2B) sectors is needed. At the moment, very little is being done in either sector. There is certainly a greater awareness of the need to separate waste streams due to the increases in local authority recycling requirements. But when it comes to lighting products, neither sector is being provided with the knowledge needed to make the right decisions.
Despite the challenges such as those described, there has been a significant increase in the amount of electrical and electronic equipment (EEE) that is recycled. But it has recently become apparent that there is still much more not being accounted for. For example, more than 50,000 tonnes of category 5 lighting EEE was placed on the market in the UK in 2014 but only 1,800 tonnes was collected. As most construction work in the UK is refurbishment, it is reasonable to assume that most of these new products are replacing older lighting types, so where are they going?
The answer seems to be that much EEE is essentially deemed to be ‘scrap metal’ and goes to Authorised Treatment Facilities (ATFs) rather than to Approved Authorised Treatment Facilities (AATFs). As the former are not required to work within the WEEE Directive, this EEE does not get recorded and may well account for the disparity mentioned above.
A concern here is that while many end-of-life light fittings may appear to be simply made of metal and plastic, they may well also contain lamps and batteries that should be disposed of through the AATF route. Again, a big issue is that electrical contractors carrying out refurbishment work may not be aware of such issues and the importance of separating waste appropriately.
This further reinforces the need for improved education across the waste disposal industry. In the B2B sector an obvious solution is to allow not-for-profit compliance schemes such as Lumicom to take care of the whole process. In the B2C sector the way forward is less clear but it is important to have the debate and explore the options.
Simon Cook is head of sales at Lumicom