The Compliance Fee is a legitimate way for schemes to comply, without having to collect every last item of WEEE towards their annual target.
In addition to this function it also has other implications on the WEEE system. These include keeping the cost of compliance in check and balancing a changing materials market, impacting the appetite to work harder towards the collection and treatment of WEEE.
For the 2016 compliance period we have seen quarterly data suggesting that the UK is well on track to meet the targets, so the need this year for a Compliance Fee that allows under-collecting schemes to top-up seems unlikely, on the face of it.
Three proposals under consideration
There are three Compliance Fee methodology proposals under consideration by Defra for 2016 that have come from the Joint Trade Association (JTA), Valpak and T2E. The key features of each are:
This sees an addition of a two tier escalator for streams with a net surplus, imposing a higher fee for a given shortfall than the standard escalator. Otherwise it is the same escalator model as the current system, with higher rates the further a compliance scheme is away from their recycling target, as per the previous years adopted mechanism.
Higher entry fee, benchmarking to the Reg 34 collection costs for Local Authorities (where the surplus WEEE is most often from expensive categories). Offsets an under collecting category against over collecting categories, with an escalator model based on earlier JTa proposals.
T2E is the organisation most recognised for trading and brokering PRN’s for the packaging compliance system. With a good background in brokering evidence the model looks straight forwards but not as sophisticated as the other offers. There also doesn’t appear to be a stand out third party authority to analyse the integrity of the data supplied like an qualified accountant, which is probably a contributor to the apparent low administrative fees charged.
Pragmatic approach to WEEE recycling targets
As a scheme we are in favour of the existence of a Compliance Fee because of the broader positive market implications it brings. It also allows a pragmatic approach to WEEE recycling targets, removing the need for a per-kilo level of granularity which has been costly and unnecessary in the past.
So far the JTA model has served its purpose for the last two years by allowing all schemes to meet their members' recycling obligations. The entry fee and the use of the Reg 34 collection requests proposed in the Valpak model could lead to higher costs in the Compliance Fee, where the system is used as a top-up system. This may further deter schemes from using the Compliance Fee, despite the late stage of the year these details are released, and time remaining to alter collection strategies.
Ecosurety continues to support the existence of the Compliance Fee, but not to call upon it. Rather we choose to invest in our own re-use and recycling systems that we have established with our preferred partners, as well as developing the self-supply collection systems of our members to meet the overall WEEE recycling targets.
The 2016 Compliance Fee proposals were published on 19 October and are under consultation until 25 November 2016.
If you‘d like to discuss your WEEE compliance, please contact our specialists on 0845 094 2228 or email firstname.lastname@example.org.
Following a brief career in the legal industry, James joined the compliance team in August 2012, and since has undertaken a variety of roles in account management and scheme operations.
He now holds the role of Technical manager where he is responsible for ensuring Ecosurety and its members are compliant across the packaging, WEEE and batteries regulations. In addition, he also leads our technical service delivery team who support clients with various data projects and international compliance activities.