ERP UK contributes to stakeholder consultation on WEEE report

The UK government plans to consult on changes to the WEEE Regulations later this year. As preparation for this, the Department for Environment, Food and Rural Affairs (Defra) commissioned consultancy Eunomia to consider the essential characteristics for a successful extended producer responsibility (EPR) scheme for electrical and electronic equipment (EEE) and to review the current UK Regulations. Read the full report here.

As one of the largest WEEE compliance schemes in the UK, and one with a longstanding commitment to ensuring a fair and effective EPR regime for producers, ERP UK is actively involved in these discussions – working both individually and with other stakeholder groups. 

ERP UK has worked closely with the Joint Trades Association (JTA) – a group of 10 producer trade associations in the electrotechnical sector – to produce a detailed critique of the Eunomia report, which will be submitted to government together with a short ‘wish list’ of key policy elements the group would like to see.

Eunomia has considerable EPR knowledge – as a result of preparing various reports for the European Commission, as well as for UK organisations – and the information on WEEE systems in other member states is a significant and useful feature of the report.

However, their perspective on some aspects of the UK’s current WEEE system is contentious. In particular, ERP UK is concerned that Eunomia take a rather ‘pro-monopoly’ stance in their report, including proposing a monopoly producer responsibility organisation (PRO) as one of four possible future options for the UK’s WEEE system. 

This seems likely to be driven by strong advocacy from Eunomia for eco-modulation within WEEE EPR (this topic comprises more than 18 pages in the report) on the basis that this would be a policy driver for eco-design.

ERP UK’s longstanding position is that competition is an essential element of successful EPR systems – as they ensure proper service and price levels for producers – but it is also convinced that models are available to implement EPR fee modulation in competitive regimes, which do not require schemes to compete on modulation.

This is why ERP UK has separately carried out a detailed examination of the report’s references to the potential advantages of a monopoly EPR regime, checking on the facts behind the general examples provided, which it has also shared with the UK government and other stakeholders.

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