years of WEEE in the UKContinual evolution10 Championing choice: producer pioneers

ERP 10 Year Report 3ERP 10 Year Report2

Through our successful lobbying for changes to the UK WEEE Regulations in 2013 we demonstrated clearly our ability to work with producers and other compliance schemes, trade associations and producer groups to address unfairnesses in the UK system.” John Redmayne ERP UK General Manager

Championing choice: producer pioneers

Founded by producers for producers, producer interests have always been central to ERP’s objectives. Producer challenges have changed dramatically over the last decade, following the introduction of the UK WEEE Regulations in 2007, and so too have the opportunities. ERP was created in 2002 as the first organisation to provide pan-European take-back schemes for the collection and recycling of e-waste. The founding members’ core mandate was to introduce a choice for compliance in a marketplace that was often dominated by a sole provider. Research has shown that creating healthy competition makes the compliance landscape fairer for producers, who were often overcharged. Just as cost is important, so too is quality. Driving

up the quality standards of WEEE treatment was another key mandate.

To create a healthier compliance marketplace with more high-quality options for producers, several things had to happen. Firstly, producers’ voices needed to be heard. Since its formation, ERP has worked particularly hard in this regard. Both in the UK and across Europe, ERP has worked with, and for, as many producers as possible to create a stronger voice to lobby for fair legislation.

“Our lobbying has always been based on facts and statistics,” explains Umberto Raiteri, ERP CEO. “Through a positive collaborative approach, we’ve been able to participate in discussions based on experience and data. This less aggressive, less confrontational, and more positive approach is appreciated, and has enabled us to protect our members’ positions and ensure they are not faced with unsustainable obligations and targets.”

Following the introduction of the WEEE regulations in 2007, the biggest challenge for UK-based producers was the ‘must buy’

system in place for the recycling of WEEE. The crux of the problem was that the ‘must buy’ system encouraged price hikes in the costs of obtaining evidence for recycled WEEE, particularly at the year’s end. The result was a closed market in which over-collectors profited at the expense of producers and other stakeholders. Essentially, there was no incentive for a producer compliance scheme (PCS) to lower prices and attract new members even if it had excess WEEE, as surplus evidence could always be sold to PCSs in deficit. PCSs then had to buy at the quoted price to meet obligations, or else face sanctions. The closed system embodied many of the inequalities that ERP had been formed to challenge, with producers unjustly footing the bill.

ERP led the charge in forcing action on the issue. Collaborating with producers, other PCSs, producer groups and trade associations, ERP lobbied to make producer voices heard. The facts and figures were carefully considered by the UK Government, and ERP recommended rationale-based changes to the

UK WEEE Regulations in the most progressive and mutually beneficial way possible.

The positive approach was effective. A landmark change came in 2013, when the UK WEEE Regulations introduced compliance targets which are clearly set and applied each year, and a compliance fee for schemes that have not managed to collect enough. The result is a more balanced system, which strives to recognise all players in the process, ensure that quality treatment standards are applied more consistently, and that WEEE traceability is in place, resulting in a more efficient recycling loop and a healthier environment.

The last 10 years have also seen increased quality of WEEE treatment. “WEEE treatment processes have become increasingly efficient in the last decade, with improved removal of regulated substances,” observes Dora Caria, ERP Quality and Audit Manager. “Furthermore, we’re monitoring recycling performance more effectively, through auditing and conducting technical studies. These activities are important to make sure that recovery rates are accurate

and that treatment complies not only with legal regulations, but also specific contractual requirements for certain producers.”

Continuing to improve the quality of WEEE treatment is paramount, as it greatly helps producers. Small producers can focus on achieving peace of mind – without getting involved with the details of WEEE treatment quality – because of the certainty that they have complied. Larger producers, and producers with electronics as part of their core business, for example, benefit massively from the assurances that come with high-quality treatment, ensuring they’re satisfied with elements beyond compliance.

“Over the last 10 years, we’ve noticed that these producers typically want to follow up and gather detailed treatment KPIs to ensure thorough and high-quality treatment,” Dora Caria explains. “These KPIs minimize risks and can be fed into CSR reports.” This is increasingly important as it helps producers to promote and maintain their image. Detailed KPIs, along with audit summaries and supply

“

July 2009

ERP UK starts operating as a packaging compliance scheme

January 2010

UK Waste Batteries Regulations enter into force; ERP UK starts operating for batteries

October 2010

ERP celebrates recycling 1 million tonnes of WEEE across Europe

washing machines recycled by ERP UK

mill

ion

+3July 2007

UK WEEE Regulations enter into force; ERP UK starts operating for WEEE

2013

New WEEE legislation comes into force

2014 onwards..

Championing choice: producer pioneers

January 2017

ERP UK takes over the compliance and data services previously provided by DHL EnviroSolutions

June 2016

ERP UK celebrates recycling 500,000 tonnes of WEEE across the UK

May 2014

ERP celebrates recycling 2 million tonnes of WEEE across Europe

January 2014

Recast UK WEEE Regulations enter into force (ERP UK lobbied successfully throughout 2013 to secure the best changes for producers)

January 2016

‘Dual use’ comes into effect, bringing many more products under the scope of household WEEE compliance, and printer cartridges with electronic components also come into scope.

10.4televisions recycled

by ERP UK

million +

We’ve been effective at sharing the learning, which is hugely appreciated by local and European legislators. Through our data collection, we’ve been able to provide benchmarks on collection and return rates, which again is appreciated as it’s helped to set targets.” Umberto Raiteiri ERP CEO

chain reports, also give producers a far more rounded view of their business.

Though the compliance marketplace and UK WEEE regulations have evolved for the better over the past 10 years, producers still face challenges. Speaking about other impactful challenges in the last decade, Umberto pinpoints ever-increasing targets as an issue: “The most important counter measure is to keep producer costs as low as possible, enabling them to meet stringent targets and ensuring as much WEEE as possible is recycled through recognised channels.” He also stresses

the importance of awareness programs in counteracting the scarcity of waste in the system. Again, this emphasises the need to ensure WEEE is recovered and treated through approved systems.

ERP’s growth and success over the last 15 years means its UK producer members are well positioned. As the only pan-European scheme, best practices are observed both in the UK and across the continent. “We’ve been effective at sharing the learning, which is hugely appreciated by local and European legislators,” explains Umberto. “Through our

data collection, we’ve been able to provide benchmarks on collection and return rates, which again is appreciated as it’s helped to inform targets.”

UK producers face some uncertainties in the next decade, not least Brexit, further increased targets, and other regulatory changes, but as far as compliance goes these are manageable challenges. So long as producers’ freedom of choice is protected by ERP, and other producer champions, the future looks bright.

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ERP UK Limited is registered in England and Wales (05859725).

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