Impact of the WEEE Directive on

Recycling of Gas Discharge Lamps

Alex Hawkins - RecoLight

www.v

oltimum

.co.uk

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Presentation to Electrex

on behalf of

www.voltimum.co.uk

NEC 18th May 2006

Subject/Content

• Impact of the WEEE Directive on Recycling of Gas Discharge Lamps

– What is the WEEE Directive

– What products are in scope

– Impact on lamp producers

– Recolight Approach

– UK Status

Introduction

• Alex Hawkins – Recolight Ltd

• Recolight Ltd – objective is to operate a WEEE Compliance Scheme in respect of Gas Discharge Lamps

• Similar approach in other EU countries – Co-ordinated via ELC (European Lamp Companies Federation)

What is the WEEE DIRECTIVE ?

Waste Electrical and Electronic Equipment Directive

Legally binding EU directive

Purpose of the directive is to prevent waste or to reduce waste by re-use or recycling

Seeks to improve the environmental performance of all parties involved in the life cycle e.g. producers, distributors, users, consumers etc

Which products are covered? Small household appliances Large household appliances IT and telecommunication equipment Electronic entertainment equipment Lighting - Lamps (excluding incandescent and halogen) - Luminaires (excluding domestic) - Equipment for controlling and/or spreading of light Electrical and electronic tools Toys and sports equipment Mechanical appliances Surveillance and control instruments Automatic distribution equipment

Gas Discharge Lamps

Filament lamps are excluded e.g. GLS, Halogen

Lamps affected by WEEE Directive

100 million gas discharge lamps sold in UK each year

Estimate between 15% - 20% currently recycled

80% weight of what is collected must be recovered

New requirements for “producers”

Basis of WEEE is producer responsibility for separately collected waste:

“Producer is at least responsible for the financing of collection, treatment, recovery and environmentally sound disposal of his products at end-of-life stage”

Definition of Producer:Organisation or person who first puts the product on the market in the UK e.g.: Manufactures and sells products (Manufacturer) Resells under his own brand products produced by another manufacturer (own-

brander) Imports products into the UK on a professional basis and first puts them into

the market (Importer)

Discharge the obligation Individually or collectively via a Compliance Scheme

Pass on costs only i.e. not-for-profit activity

Unique WEEE Issues for Lamp Producers

• Recycling cost impact as % of sales price:– TVs, DVDs, White Goods etc: typically 2% - 5%– WEEE Lamps – typically 10% - 80%

Critical for all Producers to ensure costs are as low as possible on a sustainable basis to minimise user price increases

• Multi-use: WEEE Lamps are used everywhere by everyone!Big quantities!! e.g. estimate = 80% total WEEE by pieces and 1% by weight

– Costs to sort into categories e.g. “new vs historic”, “ household vs non-household”, like-for-like vs new or into brands will be huge and on top of the collection and recycling costs

Producers need to minimise costs of sorting!

Producer Options and Tasks

1.Do-it-Yourself – example tasks:– Registration details including sales info. – Arrange & manage collection and recycling process– Communicate to and monitor the market to ensure all comply– Gather statistics/keep records/report to Gov’t

Manage the process & costs directly, or just pay costs?

OR

2. Join a Compliance Scheme, such as Recolight, who will take over Producer’s legal obligations. Producer would then only need to:

– Provide registration & sales information to Recolight – Pay their share of costs in the form of a “recycling charge” per lamp

Registration Process

• Environment Agency = responsible • Independently or via Compliance Scheme• EA will specify the Registration form e.g.

– Company details– Type of Products sold– A base year of sales-data (at present this would be

2005)• EA will allocate share of “historic” (up to 2011)• Producers or Schemes have to report their results each year• Registration process:

– Starts after legislation issued – legal requirement– Will be to a timetable (to facilitate allocation)

Registration via Recolight

• Launch an interim Pre-compliance information service:

• RAMIS (Recolight Advance Membership Information Service)

• Benefits:

– Allows Producers to demonstrate their intention to comply

– Provides access to more qualitative info

– Enables Recolight to plan better

– Adds to the Voice of Lamp Producers

– “Membership” of the Brand

• Lamp Producers only i.e. same criteria as full registration

• Will discontinue when full scheme launched

Recolight Proposed Compliance Scheme

The Company was founded by GE, OSRAM, Philips and SLI

Set up to manage a WEEE Compliance Scheme and handle the WEEE obligations of all lamp producers who join.

The Scheme itself is open to all Producers on equal conditions and all are encouraged to join

Strictly not-for-profit organisation

Operational plan has to be signed off by Government and be consistent with competition law before operations can start

Actively monitor market for free-riders on behalf of its members to ensure a level playing field

Compliance Scheme tasks

Same as Producers with the addition of:

• managing the best interests of its members (service and costs)• Setting up & operating the Compliance scheme process

Total costs charged back to members pro-rata to volume

Recycling charge: Total WEEE costs No. of lamps sold x Est Collection %

Recolight Approach (keep it simple)

Collective system - open to all producersSorting lamps by individual brand is very expensiveHistoric waste (up to 2011) is a collective responsibiity Reduction of duplication

Support idea of a flat, visible fee - same fee for all lamp typesFlat fee is simple to administer + helps keep costs lowVF gives full cost transparency and understanding by all users

Legal Requirement to Register & take responsibilityA simple solution is to join a Compliance Scheme (Recolight or other) Individual route could be time-consuming/distracting?

A cost effective, non-profit and transparent solution to meet the obligations of the WEEE directive

Proposed Collection Process

• Cannot be fully defined until legislation finalised

• Recolight proposal:– Effective network of Collection Sites – easy access & cost

effective– Building on existing trends:

• Local Authority sites for Household waste

• Dedicated sites where sufficient volume to justify

• Commercial Collection points for small-medium businesses

– Mutual efficient criteria to control cost impact

• Producer responsibility starts with collection from these sites

Current UK status

• December 05 Government announces review of progress with new Consultation Spring 06

• Publication of Regs to follow – assume Oct 06

• Implementation date = ??

• Already implemented in most EU countries

• Ongoing increase in Lamp recycling due to e.g.– Landfill restrictions from July 04– Hazardous Waste Regs from July 05

Summary

• Are you a Producer?

• Which Compliance route?

• How will the WEEE Directive impact your business?

• What Can you do now?• RAMIS

• Monitoring development of the legislation? • www.recolight.co.uk - gives links to various websites

Thank you

Thanks for your attention

Questions ?