The fee is an alternative mechanism used by compliance schemes and obligated business if they have insufficient recycling evidence to meet their WEEE collection targets for the year.
Defra’s consultation, launched on 17 October, contains two proposals from external organisations for a compliance fee methodology and administrator for 2022.
Once again, the proposals have been put forward by compliance scheme Valpak and the Joint Trade Association (JTA), a group of product-focused trade associations which work on policy issues around producer responsibility.
A JTA-proposed methodology has been used to determine the fee in five consecutive years (see letsrecycle.com story).
Defra says its consultation, which runs until 14 November, will be of interest to producers of EEE, approved producer compliance schemes, WEEE treatment facilities, waste management companies, electrical re-use organisations and local authorities.
Valpak
Valpak told letsrecycle.com that its proposal for the methodology includes an escalator that places a premium on re-use evidence.
“With the upcoming WEEE consultations, it is vital that re-use is encouraged and has appropriate economic levers to make it commercially viable, given its higher ranking within the waste hierarchy,” James Armitage, Valpak’s commercial operations analyst, said.
Mr Armitage said Valpak had made “small adjustments” to the impact of its local authority collection uplift mechanism in recognition of inflationary cost increases, while retaining it to encourage schemes to operate direct collections.
And, Mr Armitage said Valpak had recalculated its administration charge to be “more reflective” across all WEEE streams.
He added: “Our compliance fee proposal is a robust methodology and includes innovative mechanisms to encourage desired action within the WEEE system by schemes.”
JTA
The JTA is a group of 10 trade associations representing EEE producers. One of its members is techUK, the trade association for the information and communication technology and consumer electronics sectors.
Craig Melson, techUK’s associate director for climate, sustainability and the environment, told letsrecycle.com his association supports the continued use of a compliance fee and the JTA proposal.
“We feel the innovative ‘surplus escalator’ will help to drive compliance through collections,” he said. “The very real threat of a major economic downturn and recession means the option of a new cost-of-living focused methodology that ensures producers only finance WEEE that actually arises could be vital as many producers may struggle during the coming months.”
Mr Melson said techUK was “concerned” that Valpak’s proposal may “materially underestimate the cost of overheads” and so could breach the requirement in the WEEE regulations that the fee be set at a level that encourages collection.
“Furthermore, the JTA is a representative body with all stakeholders represented so proposals have been developed in consensus with schemes and producers,” he said.
Related link
Consultation on WEEE Compliance Fee Methodology 2022
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