The Environment Agency has released guidance on what data should be included by producers of EEE and batteries in the UK.
It seeks to clear-up confusion over the definition of "Placed on the Market".
Producers of EEE and batteries are required to report the weight of the products they placed on the UK market. There has previously been some confusion about when products are deemed to be "Placed on the Market", as the term is not defined within either regulation. Many producers have used sales information to approximate this figure. However, the new guidance explains that all products entering the UK and made available for sale to UK customers, regardless of the actual end destination, should be reported under the regulations.
Products that arrive in the UK and are subsequently exported may only be omitted if it is known at the time of import that they will be exported or there is evidence to suggest they were always destined for export (instruction booklets, non-UK voltages, specifications, packaging). Only battery producers are invited to voluntarily provide data to their compliance scheme regarding the amount of products sold to customers outside the UK that were deemed to be placed on the UK market. There is no provision for export reporting in WEEE.
We welcome this information from the Environment Agency. However, we do not feel that producers should be obligated to recycle batteries that do not end up in the UK waste stream. We have fed back member opinion to lobby government to make changes, as part of our own feedback, and through contributions to the stakeholder groups we actively participate in. In the next revision of the regulations, we hope to see exported products discounted from producers' obligation in a similar way to that which currently exists for the packaging regulations.
Robbie Staniforth
Innovation and policy director
Robbie is innovation and policy director at Ecosurety. Having spent years building an intimate understanding of the industry’s policies and politics, he uses this knowledge to help shape new legislation and oversees Ecosurety’s growing portfolio of cross-industry innovation projects including Podback and the Flexible Plastic Fund. He has worked closely with Defra during the most recent packaging consultations, outlining the impacts and required transitional arrangements of the UK’s new EPR system and is a member of the government’s Advisory Committee on Packaging (ACP). He is also a spokesperson for the company and regularly uses his influence to communicate the importance of environmental responsibility to external stakeholders.
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