Before we know it 2019 will be upon us, and in the world of WEEE a key landmark approaches.
For those unfamiliar, the current WEEE regulations will not only move to widen the scope of EEE with effect from 1 January 2019, but there will also be a re-categorisation from the existing 14 categories down to only 6. That’s nearly three years away - but what should you be doing to prepare for the inevitable change in current practice?
Ever since the recast of the WEEE regulation in 2013 (as a result of the recast WEEE Directive), policy relating to the upcoming change in reporting has been a hot topic in industry forums and even today it is still in development.
Why is this? Well, primarily because of open scoping. This will mean that all EEE will be required to be reported unless the exemptions or exclusions contained within Regulations 7 and 8 of the current WEEE regulations apply. It is certain to pose a big obstacle for some producers, given diverse and large selections of products which previously were not accounted for within EEE reporting.
Additionally, the focus of much policy debate is centered on how the UK will conform to the Directive’s requirement that EEE data is reported in the reduced six categories. Numerous options have been proposed and you may have already participated in producer feedback at the end of 2015. If the regulations remain in their current form, where these six new categories will become a reality, businesses need to prepare themselves to engage in further scoping of their complete product lines (whilst also considering the open scope implications above), within these new categories.
Whilst the theory of re-scoping products may appear trivial for producers with limited product types which fall quite neatly within the new categories, when you begin to extrapolate this to many thousands of product lines, with variances in size and function, before long a monster has presented itself.
I return to my first statement. Before we know it 2019 will be upon us. We do not have a final decision on what option will be agreed upon yet and we do not anticipate that we will have one until the latter stages of 2016. We do understand however that for many companies, two years simply isn’t enough time to make the changes required to meet this January 2019 implementation date, if the category reduction is decided on.
This is a good time to point out that this article is not designed to instil fear but to provoke engagement with what is happening within the WEEE regulations. It doesn’t mean you need to start writing to the Environmental Regulatory Team at DEFRA, since we have already been contributing producer feedback into DEFRA working groups, but at least start to consider your internal reporting systems and whether they are capable of effecting a change in category reporting by January 2019.
For example you need to consider how long these changes to your systems will take to implement, how you will go about re-scoping products and what training your staff will require to carry out this task effectively.
If you do have feedback that you would like to give to the regulators, please think about channelling this through ecosurety as we are in direct conversation with DEFRA and industry working groups engaged in discussion and eventual policy decision on this subject.
At ecosurety we specialise in technical knowledge of the changes. We contribute to policy discussion and encourage feedback from our members on legislation changes which will ultimately affect their compliance with producer responsibility. The more producers who provide feedback on the changes will provide a stronger voice and influence on eventual policy decisions.
We can support your individual feedback into the decision making process in the longer term, and whatever the outcome of the proposals - I encourage you to utilise our wealth of experience within the industry to support your business and your colleagues with the changes ahead.
Contact our WEEE specialists if you would like to find out more by calling 0845 094 2228 or email WEEE@ecosurety.com.
James joined the compliance team in August 2012 and now holds the role of technical manager. He is responsible for managing all regulator requirements across packaging, WEEE and batteries compliance regulations, and for overseeing our WEEE and batteries collections. In particular, James takes an active interest in quality improvement both for clients' data methodologies and internally to improve business efficiency.
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