Summary of responses and government response

Question 1

Government response

Accepted Answer

The UK government, Scottish and Welsh governments and the Department for Agriculture, Environment and Rural Affairs in Northern Ireland (DAERA) are grateful for the responses to this call for evidence. We are continuing to consider all proposals within the call for evidence and the associated consultation and will set out our response to those proposals in 2025.

We are committed to a shared priority to drive a circular economy across each of the 4 nations. Such an approach can stimulate economic growth, protect the environment and create social value.

That commitment to the circular economy is deeply embedded in respective strategies of the Scottish government, Welsh Government and DAERA:

Scotland: Circular economy and waste route map to 2030
Wales: Beyond Recycling
Northern Ireland: draft Circular Economy Strategy for Northern Ireland

The UK government will publish a circular economy strategy for England next year. It has formed a Circular Economy Taskforce, comprising members from industry, academia, and civil society from across the UK to lead the development of that strategy.

Discussions between the 4 nations on policy development on material resources and waste related to electrical and electric equipment will continue with the responses to the consultation and call for evidence informing those discussions. The UK government, Scottish government, Welsh Government and DAERA will set out plans for wider reforms that reflect their strategic priorities in the drive towards a circular economy across the UK next year.

Question 2

Summary of responses

Accepted Answer

We received a total of 122 separate responses. Not all responses considered all questions. We received responses from a range of stakeholders, as set out in the table below.

Table 1: Responses by organisation type

Respondent group	Number of responses
Local government	25
Electronic producer	24
Trade body or other business representative organisation	21
Individual (not representing an organisation)	13
Charity or social enterprise	11
Producer compliance scheme	9
Non-governmental organisation	4
Distributor (including online marketplace)	3
Reuse or repair operator	3
Waste management company	3
Waste operator or re-processor	3
Academic or research	1
Community group	1
Consultancy	1
Total	122

Chapter 1: Full net cost recovery

This chapter sought evidence on whether or not the cost of certain waste management activities related to WEEE should sit with producers. This included whether producers should fund the cost of WEEE that has been fly-tipped, littered or wrongly discarded in the residual waste bin.

Question 5: Considering the points for and against set out in the call for evidence, please select which of the following activities producers should finance the cost of:

WEEE in the residual waste
Fly-tipped WEE
Littered WEEE

Response	Number of responses
WEEE in the residual waste	51 (98%)
Fly-tipped WEEE	42 (79%)
Littered WEEE	43 (83%)

No producers or distributors answered this question.

Question 6: Please provide evidence of the volume (tonnes) of WEEE arising at UK level or by nation level in residual waste.

Some respondents referred to the Material Focus study report that identified 155,000 tonnes while another said this has recently been revised in an updated study to between 97,600 and 107,000 tonnes per year.

A limited number of local authorities provided figures based on their residual waste sampling. Resource Efficiency Wales highlighted WRAP Cymru’s 2022 report which contained figures indicating 1.7% of residual waste collected at kerbside is WEEE and 2.5% for black bin residual waste at household waste recycling centres (HWRCs).

Question 7: Please provide evidence of the volume (tonnes) of WEEE arising the UK level and or by nation that has been fly-tipped.

Most respondents were unable to provide data on this. One respondent quoted 2023 data from Defra that there were 50,000 incidents of fly-tipping of white goods and 18,000 of other electrical products in 2021 and 2022 out of a total 671,000 incidents. Resource Efficiency Wales referenced the Welsh Government’s statistics page. For 2022 and 2023 this showed 2,072 white goods fly-tipping incidents across Wales and a further 601 electrical categorised incidents.

Question 8: Please provide evidence of the volume (tonnes of WEEE) that has been littered.

There were limited responses to this question. Some respondents cited the Material Focus study which estimates that around 5 million vapes are being thrown away every week in the UK.

Question 9: Please provide evidence of the net costs per tonne for collection of WEEE arising in residual waste.

Most respondents were unable to provide data on this. One local authority provided a figure of £72.56 per tonne for disposal and another a figure which equated to £120 per tonne. Another response highlighted the differences in costs between various WEEE streams, providing a figure of £11,500 tonne for vapes.

Question 10: Please provide evidence of the net costs per tonne for collection of WEEE that has been fly-tipped.

Most respondents were unable to provide data on this. One local authority provided a figure of £29 if handled on an individual basis whilst another observed that costs would vary considerably depending on the type of waste, location and whether this was part of a wider clearance process. One waste management company indicated that fly-tipped fridges would cost £70 per tonne and TVs and monitors at £300 per tonne to process.

Question 11: Please provide evidence of the net costs per tonne for collection of WEEE that has been littered.

Vapes were the only WEEE item respondents suggested were being littered. Producer compliance schemes estimated the cost of recycling littered vapes could be up to £20,000 per tonne.

Question 12: Please provide evidence of the types of WEEE commonly discarded in the residual waste stream.

Respondents noted that small electrical items were most likely to end up in the residual waste stream, including items such as toasters, kettles, hair and beauty products, cables, chargers, toys, lamps, keyboards, games consoles, and microwaves, radios, phones, lighting, batteries, electric toothbrushes, remote controls and vapes.

Question 13: Please provide evidence of the types of WEEE commonly fly-tipped.

Respondents noted that large, bulkier items of WEEE were most likely to be fly-tipped, including fridges, washing machines, dish washers and large TVs.

Question 14: please provide evidence of the types of WEEE commonly littered.

Most respondents answered that vapes were commonly items of littered WEEE.

Chapter 2: Allocation of costs

This chapter sought views on how the existing regulations provide for setting collection targets and apportions financial obligations to producers of electrical equipment. It also sought views on an alternative approach to target setting, known as an allocation system, whereby producer compliance schemes are allocated specified local authorities to work with.

Question 15: Do you agree or disagree that we should establish a rolling 3 year process for setting the financial obligations of producers to create more certainty in the system?

Response	Number of responses
Agree	45 (47%)
Disagree	7 (7%)
Unsure	44 (46%)

Question 16: Please provide evidence of whether or not setting a rolling 3 year forecast would provide more certainty in the system and act to encourage increased investment by the treatment sector. 

Producers and local authorities who agreed said that marginal benefits can be gained from a 3 year rolling forecast, because it will provide producers and recyclers with an indication of future financing and volume requirements. However, it was noted that market circumstances will always need to be considered when setting the actual forecast for a specific compliance year, and so any targets for future years could only be indicative.

Those who were unsure said that it was unclear how moving to a 3 year process would automatically create the conditions for new investment – unless the targets (or projected arisings) are set to be more ambitious as part of the transition.

Question 17: Please provide evidence of whether or not a 3 year forecast to set financial obligations should be supported by a 3 year minimum Producer Compliance Scheme (PCS) – designated collection facility (DCF) contract duration in order to encourage increased investment by the treatment sector? 

Producers and local authorities who agreed said that a 3 year term on PCS-DCF contracts would create additional certainty necessary to encourage investment in the treatment sector. They also said that it would ensure local authorities have a collection system in place and provide a steady flow of material to recycling facilities.

Those who disagreed suggested producers would not want longer contracts with PCSs without the security of price guarantees and this could not be offered by PCSs whose membership and therefore market share can vary annually.

Question 18:  What are your views on the idea of establishing an allocation system as an alternative way to set financial obligations on producers and guarantee the financing of local authority collections? 

Producers favoured an allocation system considering that it would be fair and low cost, minimise administrative cost, provide a mechanism for all PCSs to be active in WEEE collection, and eliminate the need for the Producer Balancing System.

Local authorities were against the introduction of an allocation system as were treatment operators. There was concern that it could reduce competition in the market leading to less innovation, less improvements in service provision and less competitive costs. They felt the system should remain a free market.  Some commented that an allocation system had been previously considered and were not sure what had changed to justify reopening the discussion.

Question 19:  Please provide evidence on the estimated costs and monetised benefits of both establishing and operating such a system. 

Most respondents were unable to provide evidence on the estimated costs and benefits of an allocation system. Those respondents who did referenced evidence from an Oakdene Hollins report, which cites that allocation systems in France, Italy, Austria, Spain, and Ireland cost between €0.3 and €1.2 million. These costs have been in place since the beginning of WEEE systems. An implementation of the allocation scheme in a second cycle could be valued at 2 to 5 times this.

Question 20: Please provide evidence of any other alternative approaches, not described in chapter 2, which you think could be suitable for allocating financial obligations on producers. 

Many producers felt that the system should adopt a circular approach by allowing producers to record any used EEE that is returned to them, upgraded or refurbished, and then placed on the market again to offset against their financial obligations.   

Other respondents observed that the current system is working well and suggested no changes. Some suggested that the compliance fee needs to be set at higher levels.

Chapter 3: Reuse

This chapter sought views and evidence on new measures that could be introduced to encourage higher levels of reuse, through in-built incentives, targets, as well as mandatory reporting of levels of reuse activity.

Question 21: Do you agree or disagree that giving a higher weighting to tonnage collected by PCSs for reuse (or preparation for reuse) towards their collection targets, than tonnage collected for recycling would incentivise greater reuse (or preparation for reuse) of WEEE?

Response	Number of responses
Agree	80 (73.3%)
Disagree	8 (7.3%)
Unsure	21 (19.3%)

Question 22: Please provide any evidence to support your answer to question 21.

Those who agreed said that a higher weighting would provide PCSs with a bigger incentive to encourage WEEE reuse over recycling, particularly if undertaken by or on behalf of producers.

Those who were unsure raised concerns around the potential of unintended consequences around confusing data, fraud and risk of driving the wrong environmental outcomes (for example, extending the life of EEE with low energy efficiency or electrical safety risks).

Question 23: Do you agree or disagree that we should introduce new targets for the reuse (or preparation for reuse) of WEEE that has been collected separately from other types of waste to incentivise more collections for reuse (or preparation for reuse)?

Response	Number of responses
Agree	63 (58%)
Disagree	32 (29%)
Unsure	14 (13%)

Question 24: Please provide any evidence to support your answer to question 23.

Those in support felt this may drive improvements in the collection route to minimise damage and ensure suitability for reuse.

Some respondents expressed concerns that introducing reuse targets may inadvertently drive the wrong behaviours and increase the likelihood of non-compliance and fraud. The distinction between reuse within and outside the WEEE system was also highlighted with significant reuse taking place through various online channels, charity donations and giving to friends and family. It was noted that working equipment should ideally not be managed within a waste environment

Others recommended further consideration is needed around how targets would be set (what data and evidence would be required) and encouraged looking into the level of reuse or sale of used equipment currently taking place outside of the WEEE system (including at non-AATF recycling facilities).

Question 25: If you answered agree to question 23, please provide evidence to indicate on which of the stakeholder groups below targets should be placed to maximise impact? Please select one of the following options: 

Producers (via PCSs) 
Retailers 
Local authorities 
Both retailers and Local Authorities 
Unsure

Responses are summarised in the table below.

Respondent organisation type	Producer	Retailer	Local authority	Retailer and local authority	Unsure
Academic or research	0	0	0	0	0
Charity or social enterprise	3	1	0	2	1
Community group	1	0	0	0	0
Distributor (including online marketplace)	1	0	0	0	0
Individual (not representing an organisation)	4	2	0	4	0
Local government	19	5	3	2	4
Non-governmental organisation	2	1	0	0	0
Producer Compliance Scheme	3	0	0	1	0
Reuse or repair operator	3	0	1	0	0
Trade Body or other business representative organisation	5	1	1	2	1
Waste management company	2	2	0	0	0
Waste operator or re-processor	1	0	0	1	0
Grand Total	44	12	5	12	6

Question 26: Please provide any evidence you have to support your answer to question 25.

Responses were broadly split between those that considered obligations should be spread through the value chain and those that considered they should fall on producers via membership of their PCS.

Question 27: Do you agree or disagree that an obligation on PCSs to provide free collection services to reuse charities and the charity retail sector for donated equipment subsequently deemed unsuitable for reuse would promote greater reuse by removing a significant cost barrier to the sector?

Response	Number of responses
Agree	93 (88%)
Disagree	3 (3%)
Unsure	10 (9%)

Question 28: Please provide any evidence you have to support your answer to question 27.

There was general agreement with the proposal in Question 27, with responses stating that this would increase charity retailers’ ability to increase the volume of second-hand electrical items that they sell, as costs associated with disposing of donated electrical items that cannot be resold are a substantial barrier to growing the sale of second-hand electricals. 

Some respondents raised concerns around logistics, whether reuse charities could become less discerning if they had access to a free collection service. Some respondents raised concerns about enforcement to mitigate the potential growth in illegitimate reuse operations.  

Question 29: Do you agree or disagree that access to data from retailers and local authorities on how much used equipment is received at these collection facilities for reuse (and consequentially diverted away from entering the WEEE producer responsibility system) would provide significant and useful new insight into volumes of equipment being reused that is not classified as waste?

Response	Number of responses
Agree	84 (83%)
Disagree	10 (10%)
Unsure	7 (7%)

Question 30: Please provide any evidence in support of your answer to question 29.

There was broad agreement with trying to capture reuse data.  It was also suggested that the duty to collect reuse data should also be applied to producers, and that such reuse data could be used to “offset” the WEEE obligation of the producer (or retailer-producer), so that both are incentivised to reduce costs by undertaking more reuse. 

Question 31: Please provide evidence (including from international sources) of other potential mechanisms to increase levels of reuse and preparation for reuse activities across a broad range of products. 

A number of ideas were recommended to increase reuse. These included:

communications campaigns about reuse
product design for reusability
modular design, standardised components, and easy disassembly for repair or refurbishment
stopping producers from using planned obsolescence
producer led and funded community reuse centres
regulations and policies that incentivise or mandate product reuse and repairability
removal or reduction of VAT on re-purposed equipment
bans on the disposal of WEEE to landfill

Chapter 4: Moving to a more circular economy

This chapter sought views on applying the principle of ‘eco-modulation’ to incentivise producer to design their product more sustainably, according to a number of specified criteria. Those producing more sustainable products would be rewarded through a reduced financial obligation compared to those producing less sustainable products.

The chapter also sought views on whether businesses who use circular economy business models such as leasing should be exempt financial obligations that support collection of household WEEE.

Question 32: Do you agree or disagree that implementing a system of eco-modulation into the UK’s WEEE system could incentivise more sustainable product design?

Response	Number of responses
Agree	57 (54%)
Disagree	39 (37%)
Unsure	10 (9%)

Question 33: Please provide any evidence to support your answer to question 32.

54% of the respondents agreed that implementing a system of eco-modulation into the UK’s WEEE system could incentivise more sustainable product design, leaving 37% who disagreed and 9% who were unsure.

Almost all producers who responded disagreed. Most organisations who disagreed felt that sustainable product design objectives are best achieved through the relevant eco-design legislation rather than the WEEE system. 

Respondents on both sides of the argument cautioned against complexity of the system, the length of time before benefits can be realised, and the uncertainty of value against the costs. There were calls for further research and engagement with industry before this is implemented. 

Question 34: If you agree with question 32, which of the following approaches would you most likely support:  

Option 1: A new system of EPR in which variable fees, based on units placed on the market (POM), are modulated through the implementation of a malus (increased fee) or bonus (reduced fee). 

Option 2: Maintain the current system of setting obligations based on a market share (by weight) approach but with that market-share modulated to reward producers whose products have the lowest environmental impact, thereby reducing their compliance costs compared to those producing more harmful products.  

Option 3: Either of the above approaches 

Response	Number of responses
Option 1	11 (16%)
Option 2	28 (40%)
Option 3	30 (44%)

16% supported a new EPR system in which variable fees, based on units placed on the market (POM), are modulated through the implementation of a malus (increased fee) or bonus (reduced fee).

40% supported maintaining the current system of setting obligations based on a market share which is modulated to reward producers whose products have the lowest environmental impact, thereby reducing their compliance costs compared to those producing more harmful products. All of the producer responses but one chose this option.

44% of the respondents voted for either of the above approaches, of which the majority were notably local governments, this was reflected across all categories of respondents. 

Question 35: Which of the following metrics should we use to prioritise products to eco-modulate?

Response	Number of responses
Total weight of the product (in tonnes)	21%
Total volume (in units) sold on the UK market	42%
Carbon intensity of the product	37%

Question 36: Which of the following criteria should be used as an effective basis for eco-modulation: 

Recycled content 
Recyclability 
Reparability 
Durability 
Energy efficiency 
Hazardous substances

Response	Number of responses
Recycled content	54 (67%)
Recyclability	65 (80%)
Reparability	63 (78%)
Durability	59 (73%)
Energy efficiency	53 (65%)
Hazardous substances	47 (58%)

There was relatively equal spread of preference across the six criteria, with reparability and recyclability claiming marginally higher votes.  Producers of electronic equipment notably opted for the recyclability criteria as an effective basis for eco-modulation. The votes from charity, social enterprise, Producer Compliance Schemes, local government and trade bodies were spread equally.

Question 37: Are there any other criteria, other than those set out in question 36, which you feel would be relevant. Please specify what those would be.

Other criteria proposed were:

carbon intensity
maintainability
impact across lifecycle
materials in product
use of critical raw materials (CRM)
conflict materials
information for reuse or remanufacture
built in obsolesce
circular businesses, for example lease or hire purchase vs owning it
modularity
use of renewable materials
use of PoPS and Brominated Flame Retardants
recycling of material in UK
demand for material
how vital a product is to UK economy

Question 38: How should compliance with eco-modulation criteria be verified in a way that balances cost with the integrity of the system?

Respondents were asked to select one option.

Response	Number of responses
Self-declaration	48 (58%)
Third party declaration	25 (30%)
In advance control or inspection by the authorities	11 (13%)

Around 70% of producers chose self-declaration with a further 20% selecting in advance control or inspection.

Question 39: Do you agree or disagree that eco-modulation should be supported by mandatory labelling to give consumers visibility of the extent to which the product has met certain eco-design criteria?

Response	Number of responses
Agree	65 (61.5%)
Disagree	31 (29%)
Unsure	10 (9.5%)

61.5% of the respondents agreed that eco-modulation should be supported by mandatory labelling to give consumers visibility of the extent to which the product has met certain eco-design criteria.

There were notable differences in view. 100% of local government respondents were in agreement. This was also mirrored by NGOs and community groups including 91% of individuals. 62.5% of the producer compliance schemes also agreed with this. 

On the other hand, 29% of the respondents disagreed including 100% of the producers that responded. 9.5% of respondents were unsure. 

Question 40: Please provide any evidence to support your answer to question 39.

Many respondents commented on the need for consumers to have clear information so that they could take informed decisions. The French repair index was also mentioned in a number of responses. Other respondents questioned the link between labelling influencing consumer behaviour, the proliferation of labelling requirements and access of some consumers to the labelling information, for example via QR codes.

Question 41: If you answered ‘agree’ to question 39, in which format do you think this information should be displayed?

Response	Number of responses
QR Code (or other electronic tag)	29 (40%)
Physical label	53 (74%)
Alternative format	5 (7%)

Question 42: Do you agree or disagree that products made available on the market using circular economy business models should be excluded from the calculation of collection and treatment obligations placed on producers because they will in any case be responsible for the individual product when it is returned to them becomes waste?

Response	Number of responses
Agree	50 (52%)
Disagree	22 (23%)
Unsure	24 (25%)

Question 43: Please provide any evidence in support of your answer to question 42.

52% or the respondents agreed that products made available on the market using circular economy business models should be excluded from the calculation of collection and treatment obligations placed on producers because they will in any case be responsible for the individual product when it is returned to them at the end of a hire or leasing agreement.  It would not arise as household waste. This included 87% of producers.

Most producers and trade associations suggested that such an exclusion should apply to any producer receiving used EEE for refurbishment or remanufacture (rather than just the original manufacturer), with the netting off being calculated based on an appropriate reuse weighting factor. Others would like to see a clear circular economy business model definition which avoids greenwashing. 

On the other hand, 23% of the respondents disagreed with the majority respondents from the local government, and 25% were unsure. 

Local government respondents made clear that the system should not shift overall costs to them at end of life and that costs should remain with the producer. The system should also take into account any event where the obligated producer is no longer trading.  

Chapter 5: Increasing collections of business WEEE

This chapter sought views and evidence on ways in which the business to business (B2B) WEEE system could be reformed to make it easier for businesses to ensure their WEEE is properly collected for recycling or reuse with associated costs financed by producers.

Question 44: Do you agree or disagree that the current business to business (B2B) system (EEE or WEEE that is designed for business, industry or professional use only, rather than household use) is an effective mechanism by which end users can return WEEE to producers for proper treatment?

Response	Number of responses
Agree	13 (14%)
Disagree	58 (64%)
Unsure	20 (22%)

Question 45: Please provide any evidence in support of your answer to question 44.

Most respondents, across all categories, who disagreed shared the view that the current B2B system is cumbersome and complex. This included 95% of producers and 89% of producer compliance schemes. These groups highlighted that there was confusion about who the responsibility of funding the collection and recycling of B2B lies with, noting that only a small percentage of B2B WEEE is actually being collected within the current system of producer responsibility.

All AATFs and a majority of waste management companies also shared this view, noting the volumes of B2B WEEE being reported as going through the system.

Another common theme amongst respondents is that a different approach will continue to be needed for B2B WEEE given that the nature of commercial and industrial equipment is different to that of consumer WEEE. It was noted in many instances such equipment has value when no longer required by the business end-user who will want to retain that value rather than handing over the equipment to producers.

Question 46: Do you agree or disagree that we should extend the principle of producer responsibility to the premises of the business end-user (and other non-household premises) and introduce a collective producer responsibility system for Business to Business (B2B) WEEE?

Response	Number of responses
Agree	67 (72%)
Disagree	7 (8%)
Unsure	19 (20%)

Question 47: Please provide any evidence in support of your answer to question 46.

All distributors and waste manage companies agreed with this in principle. Waste management companies did comment that issues around dual-use equipment would have to be resolved (for example, equipment designed for both household and non-household use, such as laptops), and that final holders should be allowed to make their own arrangements in respect of having their WEEE collected. Others agreed but emphasised that there must be environmental and practicable limits for collecting items in low volumes from individual businesses. 

92% of electronic producers who agreed commented on the need for a new collective B2B system that would incentive reuse and increase recycling. 8% of producers were unsure and raised doubts around how businesses with a mix of different categories of WEEE from different producers would manage the segregation of the categories and the cost to the producers involved.

20% of respondents were unsure. These were mainly local authorities (78%), who raised issues including the potential complexity of the system. It was argued that a simple system, which operated free of charge, would be most effective. 

Question 48: Are there circumstances (for example, for certain product types) in which individual producers should be responsible for the cost of collection and treatment of the products they place on the market when they become waste?

Response	Number of responses
Yes	54 (66%)
No	2 (2%)
Unsure	26 (32%)

96% of producers and 87.5% of producer compliance schemes agreed. Furthermore. 100% of distributors and 100% of waste management companies also agreed.

Question 49: Please provide any evidence in support of your answer to question 48.

Examples given by respondents across the above categories that should fall outside of the obligation included products that are supplied via circular business models, that are returned to the producer for repair, rework or remanufacture. Closed loop models in the IT sector were cited as an example. Other examples included heavy EEE above a certain weight threshold for which a collective system of responsibility would bring unfair cost allocation across producers in a given category of equipment.

Question 50: Do you agree that a system in which producers financed the cost of collection from the business end user and adequately supported by appropriate communications would be sufficient to drive increased levels of business WEEE into the system? 

Response	Number of responses
Agree	64 (72%)
Disagree	10 (11%)
Unsure	15 (17%)

100% of producers and 78% of producer compliance schemes agreed.

Question 51: Please provide any evidence in support of your answer to question 50.

As evidence, a Recolight survey was cited that found that where business end users are offered a financed waste collection, this results in materially higher collection rates. It was also argued that heavy WEEE is best managed by the business end-user, given such equipment usually has a material value.

Furthermore, 75% of local government respondents agreed. Key reasons given were that the current B2B system is not user friendly or easy to access for businesses, leading to fly-tipping. A producer funded collection system direct from the end business would be an ideal solution to ensure business WEEE is driven into the system and properly treated. 

Question 52:  Are there any circumstances in which it might not be appropriate for producers to finance collections from businesses?

Response	Number of responses
Yes	48 (55%)
No	22 (25%)
Unsure	18 (20%)

Question 53: Please provide any evidence to support your answer to question 52.

96% of electronics producers answered yes to question 52 mentioning heavy EEE over 100kg, as this usually has inherent scrap value or will require specific transport arrangements or will be subject to reuse or repair activities. It was argued that instead, heavy EEE should be subject to individual producer responsibility to prevent producers from bearing a disproportionate share of market costs.  

Other circumstances included the collection of small quantities of B2B EEE to ensure collections are environmentally and economically beneficial. Other respondents highlighted the longevity of some B2B EEE which makes it difficult for some producers. 

A quarter of respondents answered no, but no significant comments or views were given to support this.

Question 54: Do you agree or disagree that there should be a ban on producers and distributors sending whole items of electrical equipment (such as surplus stock) to landfill or incineration?

Response	Number of responses
Agree	104 (99%)
Disagree	0 (0%)
Unsure	1 (1%)

There was almost unanimous support for this proposal from across all categories of respondents.

Question 55: Please provide any evidence in support of your answer to question 54.

Many respondents stated that sending surplus stock to landfill or incineration contradicts the waste hierarchy and circular economy objectives. It was felt that unsold stock should be prioritised for resell, reuse or donation. Some respondents did note that exceptions might need to be made where the product presents a health and safety or chemical risk. 

Question 56: If a ban were to be implemented, do you foresee any unintended consequences of unwanted electrical stock being redirected to any of the following routes?

33 respondents answered this question. Some respondents chose to select multiple answers.

Response	Number of responses
Reselling	17 (52%)
Repair or refurbishment	11 (33%)
Reuse	16 (48%)
Recycling	15 (45%)

Question 57: Please provide any evidence in support of your answer to question 56.

100% of electronic producers felt a ban could impact on reselling, as there could be issues with items related to safety and warranties. It was argued that brand protection leads to product destruction but that this should not result in landfill or incineration. Instead, it was argued that communication is needed to allow producers to access a sustainable and recycled option for brand protection.  

Question 58: What are your views on alternative policies to improve the B2B system? Please provide any evidence you have to support your answer. 

Some respondents suggested that there are certain barriers which need to be addressed in order to have a functioning B2B WEEE system. This includes cultural fears over data privacy and cyber security, indirect supply chains, and the move to more hiring and leasing models.

Others highlighted that the scoping of dual use and B2B EEE leads to some EEE being treated as household WEEE when it is highly unlikely to enter the household waste stream, such as large air conditioning units. It was therefore suggested that dual use should be abandoned and the definition of B2B and B2C should be centred around how EEE is sold or arises. Other respondents suggested B2B specific targets may drive performance.  

Chapter 6: Improving treatment standards

This chapter sought views and evidence on measures aimed at improving treatment standards for WEEE, including reviewing the current recycling and recovery targets, providing better information to WEEE treatment operators and ways of recovering more critical minerals.

Question 59:  Do you agree or disagree that the recovery and recycling rates for WEEE should be reviewed to ensure that those targets remain sufficiently challenging whilst achievable?

Response	Number of responses
Agree	89 (98%)
Disagree	2 (2%)

Question 60: Please provide details of evidence sources used to support your answer and evidence on the extent current targets are being met and exceeded.

There was almost unanimous support for reviewing the existing recycling and recovery targets for WEEE. It was noted that these had not been updated substantially since 2006 and changes in WEEE treatment (for example of persistent organic pollutants (POPs) in WEEE), and advances in treatment processes and technologies, could mean that the current targets could either be too difficult or too low depending on the category.

Question 61: Do you agree or disagree that AATFs should be required to report annually on the extent to which they have met those recycling and recovery targets and that their report should be supported by an independent audit?

Response	Number of responses
Agree	77 (91%)
Disagree	4 (4.5%)
Unsure	4 (4.5%)

Question 62: Please provide any evidence to support your answer to question 61.

Question 63: Please provide evidence of likely costs of both reporting and independently auditing recycling and recovery rates.

Most respondents, across of categories, strongly supported such measures to increase transparency and stakeholder confidence in AATFs. The treatment sector also supported annual reporting (67%) although not quite as strongly. A third of AATFs disagreed suggesting that to require independent audits would add significant, and unjustified costs, to AATFs. They also state that audits would unduly interrupt operation of the facilities and would be additional to audits undertaken by regulators and their customers.

The costs of an independent audit were estimated at around £5,000 per audit.

Question 64:  Do you agree or disagree that the introduction of individual recovery targets for specific materials, including critical minerals would drive recovery of and demand for those materials thereby contributing to Net Zero and Circular Economy ambitions whilst supporting security of supply of certain materials?

Response	Number of responses
Agree	63 (70%)
Disagree	14 (16%)
Unsure	13 (14%)

Question 65: Please provide any evidence to support your answer to question 64.

In general, electronic producers agreed that individual targets would be useful. However, all highlighted that there is not yet a strong enough evidence base, which would need to be developed before any useful material recovery targets could be set. 

One trade body disagreed, arguing that targets would not drive performance changes due to limitations in infrastructure and because electronics products are designed for global markets, not just the UK. 

The waste management companies and AATFs which disagreed highlighted that we do not know the precise breakdown of individual minerals or materials in WEEE that arrives in bulk for processing. One noted that onward process of some WEEE derived material is processed in foreign refineries, that would outside of the remit of regulators. It was suggested that the government create an overall target for critical minerals recovery, rather than specific targets for WEEE, in line with the EU approach. 

Others noted that the market for recycled critical materials is very immature, so there would need to be clarity on which materials can be realistically targeted in the UK. They also noted the risk that individual targets could lead to equipment being recycled, when it could be reused. 

Question 66: If you agree with question 64:  would you support the introduction of reporting on specified materials to form a useful evidence base ahead of setting targets in the future?

Response	Number of responses
Agree	36 (51%)
Disagree	6 (8%)
Unsure	29 (41%)

Question 67:  If you answered agree to question 66, should these targets be mandatory or non-binding? 

Response	Number of responses
Mandatory	29 (52%)
Non-binding	27 (48%)

Question 68: We require treatment facilities to demonstrate sound management of WEEE, including removal of specified hazardous material and POPs. Are there any other substances and components which should be added to the restricted list? Please provide evidence to support your answer. 

Most respondents did not suggest any other substances or components which should be restricted. Most waste management companies and AATFs however did raise Per- and polyfluroalkyl substances (PFAS) as a concern and a particular challenge for treatment facilities. One suggested perflurooctane sulfonate PFOS. One relevant trade body suggested reviewing the substances of very high concern (SVHCs) under REACH and noted brominated flame retardants as an additional concern. 

Question 69: What do you think are the key barriers to improving material recovery when treating WEEE?

Respondents were asked to select one option.

Response	Number of responses
Information barrier	2 (3%)
Technological barrier	37 (51%)
Other	33 (46%)

Question 70: If you answered “other” to question 69, please specify what this would be.

A number of respondents observed that there are both information and technological barriers. Others mentioned inconsistent regulation and enforcement. Product design, ease of dismantling and current recycling processes were also referenced together with the focus on higher rather than lower value material recovery.

Question 71: What information do you think suppliers of products should be required to provide to assist waste treatment operators to increase the recovery of specific materials or components commonly found in WEEE?  

Some respondents suggested that no additional information should be required. This was largely because WEEE material is recycled at large scale, so it is not possible to check individual information for each product. The essential thing for collections is that it is clear what hazardous components are contained, as well as if there is a battery inside the product.

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