Are simple WEEE collection targets still fit for purpose?

Every year, the Government establishes a national waste electrical and electronic equipment (WEEE) collection target, split among the 14 different categories of electrical and electronic equipment (EEE). The target is then shared out amongst WEEE Producer Compliance Schemes (PCSs) based on their market shares of each category, in the prior year.

Setting the target is not easy. Set it too low, and there is a risk that the most active PCSs – those that actually collect WEEE – will end up having to finance more WEEE than their market share. That does not seem fair. But equally, if it is set too high, multi-million-pound compliance fee payments are made by PCSs, to cover their shortfall of the target. That simply adds cost. So the sweet spot is to set a target that is just above achievable.

The targets and compliance fee system has operated since it was introduced in 2014. But although targets have generally increased each year, the WEEE collected has not. The UK hit ‘peak WEEE’ in 2016, and it seems unlikely that we will again reach those levels. So setting targets is not driving up WEEE collection and recycling.

And perhaps more importantly, as the drive towards a circular economy gains real momentum, simple WEEE tonnage targets do not capture or incentivise the great circular models now adopted by some producers. A WEEE tonnage target, on its own, is no longer fit for purpose.

So how can targets within the WEEE system be adapted to ensure the right outcomes? Here are some options:

Build the infrastructure

There is considerable merit for the suggestion that the WEEE system should simply be tasked with two key objectives:

1. To set up the necessary collection infrastructure to make it as easy as possible for consumers and businesses to dispose of their WEEE correctly. That could well be achieved by the widespread implementation of a kerbside WEEE collection service for consumers and some businesses. It might also be achieved by requiring an agreed, UK wide, collection point density and distribution.
2. Comprehensive communications to both consumers and businesses, to ensure they know how to ‘do the right thing’.

Get these two right, and it could be argued that whatever actually arises is the tonnage that PCSs should finance, on a market share basis.

System impact targets

Another approach could be to use sampling to assess the tonnage of WEEE that is placed in the residual bin. That data could then form the basis of WEEE system targets: if kerbside and/or distributor collection routes are working, and if the communications messaging is encouraging consumers and businesses to dispose of their WEEE correctly, then logically the WEEE in residual should reduce.

Such targets would best be applied to a central coordinating body, if amended WEEE regulations were to require one.

Smart tonnage targets: ecomodulation of WEEE

It is difficult to see how tonnage targets could be dropped entirely – not least because they form the basis of the split of financing responsibilities between competing PCSs. But crude tonnage data could be made much smarter. Currently, a tonne of reuse evidence has the same ‘value’ as a tonne of recycling evidence, when a PCS uses that evidence to meet its target. That does not make sense, given that reuse is above recycling in the waste hierarchy.

Tonnage values could be made much smarter by applying modulators (or escalators) to the gross tonnage, as a way of better incentivising the right environmental outcomes. A few examples of activities that could be given a higher weighting include:

• Reuse rather than recycling
• Recycling or reuse undertaken in a facility that has been certified as working toward net-zero
• Used product that is put back into the market by the producer, without ever arising as waste.
• Harvesting of spare parts from used product by the producer, which is then incorporated into new products

The extent of modulation would need to be significantly material, to ensure the right behaviours are incentivised – a doubling of the value of ‘good’ tonnage when compared to recycling tonnage would almost certainly apply an appropriate driver. This methodology is in effect, the application of ecomodulation principles, but to WEEE rather than to product placed on the market. And arguably, this might be a more appropriate way in which ecomodulation should be applied in the sector.

Summary

To move entirely away from tonnage targets would be challenging – politically and technically. But to apply some or all of the approaches described here would ensure that the WEEE system was much better focused on delivering the right environmental outcomes.