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BIS issue de minimis advice to small producers of EEE
The letter highlights the likelihood that, no matter which of the four amendments are agreed upon, a de minimis threshold of 5 tonnes for smaller producers will be imposed. The threshold is aimed at those 3,420 producers from a total of 6,000 registered producers in the UK that make up 3,483 tonnes of EEE equalling 0.2% of total UK EEE.
The timing and clarity of the de minimis have been questioned by many of the UK’s leading compliance schemes. To remain compliant for the 2014 period, companies will have to have made arrangements by the 15th of November. It has been highlighted by Valpak’s Duncan Simpson that because of this narrow window, smaller producers of EEE may not have the amount of information and time required to remain compliant for the 2014 period. He goes on to empathise the importance of “clarity on the legal position for producers and schemes who decide not to register on this advice, as otherwise they would be in breach of current regulations”
Producers of less than 5 tonnes of EEE will still need to adhere to the WEEE regulations by registering with the relevant environmental agency and making sure that all electrical equipment is disposed of in a way that meets the conditions of the recast WEEE directive.
All eyes will now undoubtedly be on government and their announcement of which option will be taken forward as part of the recast WEEE directive 2012/19/EU, as well as how the de minimis threshold will be incorporated into the new legislation. The due date for this announcement has been set for the end of September, leaving barely two months for all small producers to make a decision on re-joining compliance schemes based on their production forecasts over the next year.
A decision to not re-join a scheme could result in an estimated saving to producers of EEE of 10% per tonne recycled. Caution should be taken however as companies will still need to make sure that they are compliant. Waste collection specialists such as Collect and Recycle (http://www.collectandrecycle.com/