The WEEE Regulations 2013 which came into force 1 January 2014 included a new evidence note trading system which has brought changes to the transfer of evidence between WEEE compliance schemes through Approved Authorised Treatment Facilities (AATFs) operators. AATFs have warned the government that the new trading system will add significant administrative costs to their processes.
The WEEE regulations guidance, published late 2013, states that AATFs are responsible for ensuring that evidence notes are issued only to the producer compliance scheme that will count the evidence towards its target. This differs from the old regulations in that previously AATFs would issue one evidence note per tonne of WEEE processed to the compliance scheme which supplied the WEEE. Schemes could then trade any surplus WEEE evidence notes which they accrued with other schemes which had not collected the required amount to meet their obligation.
The trading of WEEE evidence between schemes was outlawed by the BIS in the new WEEE Regulations in order to, as the department believes, reduce costs. AATF operators have expressed concerns that the changes have failed to account for new administrative procedures and updates to IT systems which will be needed in order to accommodate the new WEEE evidence note system and have warned that this will lead to delays in reporting of quarterly WEEE Recycling data.
Speaking to Let’s Recycle, Justin Greenaway of WEEE reprocessor SWEEEP Kuusakoski said: “Waste data management systems and accounting software has been developed, fine-tuned and perfected ... Now with negligible notice the fundamentals of a tried and tested reporting system is being jeopardised.”
A BIS spokesperson told Let’s Recycle: “We have received a number of helpful comments from stakeholders on the question of ‘trading of evidence notes’ between compliance schemes under the new WEEE Regulations. We are considering the arguments for and against carefully and will confirm our position in due course.” The Department will now seek stakeholder views on how to address AATF concerns.
Emily Baker, Compliance Manager at producer compliance scheme Comply Direct, believes that a transitional approach would allow for the full evidence trading system to develop and will discourage administrative costs from accumulating. She said: “The regulations were only confirmed at the last minute so it is understandable that many schemes and reprocessors feel as though they have not had adequate time to adapt their systems and plans to the new WEEE evidence trading note system.” “In many ways 2014 is already a transitional year and while there may be some small scope to continue trading of evidence between schemes, 12 months grace while the industry adapts to the new system could save AATFs money and allow producer compliance schemes to secure their WEEE evidence strategies, cutting the need for knee jerk admin and processes which could be costly and time consuming.”
Comply Direct will keep members up to date on any possible consultation or review which may ensue from the concerns raised. For more information please get in touch with the Comply Direct WEEE team and quote “WEEE evidence”.