A WEEE bit of Confusion

By Vince Eckerman of Weeeco    

There is a great deal of confusion relating to the recycling of discharge lamps and this has the potential to cause difficulties for everyone in the supply chain.

Past experience shows that almost every item of new legislation is greeted with mixed feelings, ranging from disgruntlement at the extra work involved to achieve compliance, through to a hearty welcome for the benefits it brings. Eventually, though, everyone gets to grips with the complexities and compliance becomes part of everyday life.

This has certainly been the case with most industries that are dealing with the Waste Electrical and Electronic Equipment (WEEE) Directive; which covers just about anything that requires an electricity supply to operate. However, one area that stands out from the rest for its failure to settle into a smooth and well-understood routine is the recycling of discharge lamps (fluorescent, metal halide, sodium etc). Here, the confusion appears to be growing rather than diminishing.

Lack of clarity
As a company that deals with all kinds of WEEE, from light sources to washing machines, we have a comprehensive overview of this situation, which enables us to compare the different sectors. The lack of clarity that differentiates the lamp recycling sector from other sectors is a major cause for concern. It is a concern for us because we have to work within this situation to ensure that potentially hazardous waste is dealt with responsibly. And it should also be of concern to electrical wholesalers who find themselves having to deal with end-of-life lamps. At the very least, a great deal of time will be wasted in finding a way through the tangled web that has been woven.

Before looking in more detail at where the areas of confusion lie, it’s worth reminding ourselves why the disposal of discharge lamps is so important. Discharge lamps contain mercury and sometimes traces of other heavy metals, so they are classified as hazardous waste. This means that they must be channelled into a different waste stream from most other WEEE items, to ensure that the potentially harmful substances are not released into the environment.

From a waste management perspective this has implications in terms of separating lamps from luminaires, control gear and batteries used in emergency lighting. Once separated, each of these must then be consigned to the appropriate waste stream through an accredited compliance scheme.

This highlights one major area of confusion, namely there is a wide perception that there is only one compliance scheme for discharge lamps. In fact, while there is one dominant scheme, there are an additional 32 registered schemes in the UK, all fully licensed and able to provide compliant services for discharge lamp disposal.

In parallel, there is another closely related area of confusion that has recently come to the fore. The dominant compliance scheme for lamps had assumed that it would be the sole provider for compliance, with all of the major lamp manufacturers on board. In the light of that assumption, it announced that it would collect lamps from all manufacturers, be they from consumers or businesses.

However, things didn’t pan out as anticipated and, having failed to achieve its monopoly, that compliance scheme is now backtracking on its previous promises and starting to be selective about which lamps it will take. Clearly, this is creating a great deal more confusion for wholesalers – as well as end users and their project management representatives. So this added confusion has been spread throughout the supply chain and, in my opinion, it is confusion that is totally unnecessary.

Up front payments So those are the high profile areas of confusion that many readers may already have encountered but there are also additional underlying problems that have helped to create this situation. Not least of these is the way that some of the lamp manufacturers have chosen to handle the cost of environmentally responsible disposal of lamps. This varies between the business to consumer (B2C) sector and the business to business (B2B) sector.

On the B2C front, things are quite straightforward, insofar as each manufacturer pays in proportion to its market share within its industry – and this applies to all kinds of WEEE. On the B2B side, though, the situation is far more complex. Here, manufacturers have the choice of making an up-front payment to the compliance scheme, which they then add to the cost of the products, or paying for disposal at the time their products enter the waste stream.

In most industries the up-front payment concept was rejected out of hand, because manufacturers realised they would be paying for the disposal of products that might not enter the waste stream for many years to come. Essentially it’s a basic tenet of business that you don’t tie up money when you don’t have to.

Some lamp manufacturers, though, decided they would go for the up-front payment option. Initially this was at the rate of 15p per lamp which, in most cases, was added to the price of the lamp to business customers (this only applies to B2B products). The result is that the lamp manufacturers part with a lot of money before they need to, and wholesalers, installers and end users have to pay more for the products long before they need to dispose of them. So the main winner is the compliance scheme that receives huge amounts of money many years before it needs to reinvest it in lamp disposal. In fact, the up-front cost per lamp has now been reduced because of the large sums already paid and lodged in reserve.

At this stage it’s important to point out that a few compliance schemes in other sectors have also opted for the up-front payment strategy. In these cases, however, they offer a rebate on any overpayment. This doesn’t appear to be the case in the lamp disposal sector.

Given all of these machinations within the lamp disposal industry it’s hardly surprising that many wholesalers are scratching their heads and generally getting fed up with the whole business. At the end of the day, you just want to know that they can dispose of any waste lamps quickly and easily, with minimum hassle. You certainly don’t want to get embroiled in the internal politics of the highly confused situation the lighting industry has created for itself. As I said at the beginning of this article, it’s important that legislative compliance becomes an integral part of day-to-day processes, rather than an additional headache on top of the proper job.

To add insult to injury, many wholesalers are finding that certain compliance schemes won’t collect lamps unless quite a high volume is available. So they have the added cost and inconvenience of transporting their waste to a collection centre.

In the light of all these factors it’s little wonder that many wholesalers are looking for alternative ways of dealing with their waste. For many, the answer is to employ a waste contractor that will deal with all kinds of electrical and electronic waste, provide the necessary compliance paperwork, and deal with all the political issues. And that leaves wholesalers free to focus on their core business.