Waste not, want not

The fastest-growing mountain of rubbish in the EU is that of waste electrical and electronic equipment (WEEE). This is not surprising as each household owns an average of 25 electrical or electronic appliances. When the lights go out this equipment is traditionally despatched to landfill sites where it takes up space, contaminates land, fails to decompose and wastes resources used in manufacture.

Recycling and reuse of WEEE would reduce the negative impact on the environment and conserve natural resources. With this objective the WEEE European Directive was published in January 2003, together with the Restriction of Hazardous Substances (RoHS) Directive. The RoHS Directive deals with ‘designing out’ hazardous materials during the design and production stages of electrical and electronic equipment (EEE).

These Directives have progressed through the Government’s consultation process to the final stage without sparking much interest beyond the electrical and electronic industries. Implementation in UK law was scheduled for August 2004, with ‘producer’ responsibility tripping in a year later, but the DTI have now stated that this will be later in the year.

The Industry Council for Electronic Equipment Recycling (ICER) estimates that the first year’s cost of the WEEE Directive to the UK will exceed £2 billion. In view of the high-tech nature of modern buildings, a proportion of this sum will go toward increasing the cost of construction. To establish how services contractors will be affected, the responsibilities of the individual classifications must be examined.

Who are producers?

Manufacturers are ‘producers’ and will be responsible for funding transportation to recycling facilities and the recycling process.

Businesses who buy-in components to assemble products and sell the composite, finished items badged with their name will be categorised as producers and have similar responsibilities for funding.

Passing the financial responsibility to producers incumbent on EU legislation is relatively simple, but what of EEE producers domiciled beyond the control of such legislation? In these cases the responsibility shifts to those who import the equipment into the EU. This could draw contractors who are importing equipment into the field of funding.

The financial liabilities indicated so far relate to products placed on the market after August 2005, but producers will carry the burden of responsibility proportionally for products available prior to this date. This will be financed through collective schemes. Responsibility for historical WEEE will also be developed to cover ‘orphan products’, those produced by manufacturers no longer in business.

The retailers’ role

Retailers will be classified as distributors and required to accept WEEE on a like-for-like basis against sales. They will not need to provide a collection service. The Government has proposed that retailers could meet their obligations by offering an in-store take-back facility or by joining a retailer compliance scheme. Details are not finalised and the position of the small retailer is unclear.

Equipment installers

Domestic clients/consumers will be required to pay their installer or local authority to transport WEEE to a recycling centre. Their obligations are restricted to the cost of transport, with the recycling charges being borne by the producer.

The cost of transporting WEEE stripped from a building under contract will be borne by the building owner in a similar manner to present disposal charges ie the contractor or subcontractor will include it in their tender. The equipment identified for recycling will be restricted to the categories listed below.

Installers buying EEE from suppliers will pay a visible or concealed fee levied by the producer for dealing with WEEE. These costs will be passed onto clients as part of the material/equipment cost.

Consumers are not legally bound to comply nor will they be charged a take-back fee for recycling. However, they will be required to transport WEEE to the retailer’s premises or a collection centre. New buys will incur the producer’s fee for dealing with WEEE.

The categories of equipment are of follows:

• large and small household items eg cookers, toasters;
• IT and telecommunications;
• radio, tv, hi-fi, instruments;
• lighting;
• medical devices;
• monitoring and control instruments;
• toys;
• tools;
• automatic dispensers.

Who pays for WEEE?

It is almost certain that producers will pass on their costs to retailers and therefore the consumer. Within construction, a similar situation is likely. Contractors purchasing EEE will recover the additional costs from clients. It is therefore envisaged that a proportion of the estimated cost will increase construction costs.