The Department for Business Innovation and Skills (BIS) has opened a consultation on three proposals for a waste electrical and electronic equipment (WEEE) compliance fee methodology, which respondents will have until 15 November to submit their responses to.
In 2013 BIS consulted on a recast WEEE Directive and changes to the UK WEEE system as a result of the Red Tape Challenge. One of the outcomes of this consultation was that the UK would implement a new household WEEE system based upon a collection target given to producer compliance schemes (PCSs), along with an option to pay a compliance fee (should one be approved by the Secretary of State) if a PCS failed to meet its target.
Earlier this year a number of stakeholders submitted proposals for a WEEE compliance fee methodology. Those involved in the submissions were the Association of Manufacturers of Domestic Appliances; the Environment Exchange; ESA; Joint Trades Association (JTA); Industry Council for Electrical Recycling; TechUK; T2E; Valpak; and the WEEE Scheme Forum.
Three WEEE Proposals
BIS received three proposals – from the JTA, Valpak and a “Seven Scheme proposal” developed by seven PCS, namely Advantage Waste Brokers, Dataserv Group, DHL WEEE Compliance, Veolia WEEE Compliance, Wastepack / Electrolink, WeeeCare and WE3 Compliance. This particular submission is a proposal for calculation methodology and administration of WEEE compliance fee, in accordance with Regulation 76 of the WEEE Regulations 2013 and BIS guidance, and includes details of how fees are to be calculated for each WEEE stream. Its proposal states: “The base compliance fee will be calculated as the average net cost should be weighted based on the tonnes of household WEEE collected by each PCS, so that it is not distorted by small and therefore potentially unrepresentative WEEE collections.”
Essentially, the proposal is uses an escalating cost approach. “The fee is calculated using a formula that ensures that the compliance fee per tonne increases the further a PCS is from achieving its target, to incentivise compliance by physical WEEE collections. This mechanism is referred to as the escalator,” it summarises.
The JTA’s proposal is a development of its original 2014 submission, which it says has already “been successfully implemented and operated”. It further explains: “The calculation is based on the weighted average net cost of direct collections and treatment transactions incurred by PCS’s that decide to use the Compliance Fee for a collection stream. This excludes fixed overheads and the costs of indirectly acquired WEEE evidence. A separate fee is calculated for each collection stream of WEEE.
“An escalation factor (the Escalator) will be applied to the calculation. The percentage increase in the fee depends upon how far away a PCS is from their collection target per stream. For PCS’s that marginally miss their target the effect of the Escalator will be minimal, for a PCS making no effort to achieve their collection target per stream the effect of the Escalator would be to double the Compliance Fee.”
And finally, the key points of Valpak’s proposal include: schemes providing actual direct collection and treatment cost data by waste stream; a participation fee of £2000 per scheme wishing to use the compliance fee as a contribution towards audit and administration costs; a standardised additional charge of £3.50/tonne will be made to allow for the necessary fixed costs of managing collections; and fees to be escalated by a factor related to the percentage scheme shortfall against the national target set by BIS in each stream so that a greater fee is payable for a shortfall which is more significant compared to the requirement Proposal for a WEEE Compliance Fee.