Using WEEE regulations to access free lamp recycling

Written by: Nigel Harvey, CEO of Recolight | Published:
Defra has set a target of 6,132 tonnes of lamps which must be financed by producers

Not everyone knows that waste management companies can use the Waste Electronic Equipment regulations to access free lamp recycling. Nigel Harvey, CEO of WEEE scheme Recolight explains more.

Fluorescent tubes, or lamps, contain mercury. That is the reason they are classified as hazardous waste. It is also one of the reasons why it is important to maximise their recycling rate.

They are fragile, light-weight and all too easy to lose at the bottom of a skip of general waste. They are are costly to treat, requiring dedicated facilities that can prevent the release of mercury when the tubes are crushed.

Of particular importance, they are subject to ‘producer responsibility’ as they are classified as Waste Electrical and Electronic Equipment (WEEE).

That means the producers of new lamps – including LED lamps – are responsible for financing the recycling of fluorescent tubes when they reach end of life. That financing obligation creates opportunities for those collecting waste lamps to access free-of-charge recycling through the WEEE system.

How to benefit from WEEE producer responsibility

Fluorescent tubes, and other lamps such as LEDs, are classified as WEEE in the UK regulations. This means the recycling of lamps is subject to annually set government targets.

For 2017, Defra has set a national target of 6,132 tonnes, which is the quantity of lamps that must be financed by producers, via their Producer Compliance Schemes (PCSs), under the WEEE system.

This is equivalent to around 40 million fluorescent tubes and was set by Defra in March based on its estimate of the total quantity likely to be collected and recycled this year. In other words, PCSs are expected to need to finance all the waste lamps forecast to arise in 2017.

However, many end-users and waste management companies are still charged for their lamp recycling. To access a free service, it should simply be a matter of making contact with a PCS which has lamp producer members, such as Recolight, whereby the PCS then should be able to organize and finance the recycling.

The PCS will also receive an ‘evidence note’ – a recycling certificate that proves they have recycled the lamps, and which they need to show they have met their own target for 2017.

If end-users and waste management companies don’t take this approach, then it is likely that the recycler will still be able to sell the evidence note to a PCS. In effect, receiving two payments for one recycling operation.

The latest data for lamp recycling, published in May this year, showed that 1,419 tonnes of waste lamps had been recycled from January to March 2017. This is around 92.5% of the pro rata annual target. If this situation remains unchanged, it seems likely that a number of PCSs will be actively seeking additional waste lamps in order to meet their targets.

If a PCS fails to meet its target by year end, it should have the option of paying a WEEE compliance fee. The decision if, and how, to set a compliance fee is taken by Defra after the year end.

Although PCSs do not know how much the compliance fee might be, it is expected to be higher than the typical cost of recycling. So a PCS would always prefer to comply using recycling evidence notes, rather than paying an unknown fee.

This all means that any holder of larger quantities of waste lamps should be able to arrange for them to be recycled free of charge. And that in turn should encourage more recycling – research undertaken by Recolight has shown that making lamp recycling free is a one of the main drivers of increasing recycling rates.

Sources of waste lamps

Most waste lamps arise from businesses, rather than consumers. Of the 6,138 tonnes of waste lamps collected in the UK in 2016, only 20% arose from household waste recycling centres. Businesses are by far the largest users of fluorescents – and therefore those most likely to need to recycle them.

Over the next few years, we can expect to see the overall tonnage of waste lamps collected decline, as the move towards longer-life LED lamps, and LED integrated luminaires accelerates.

Currently, LED lamps represent only about 1% of the waste lamps collected, although this will rise over time. Yet when they arise as waste, LED lamps can be collected in the same container as fluorescent lamps.

That is the result of a pragmatic position adopted by the Environment Agency a few years ago, recognising that most end-users cannot easily distinguish one lamp technology from another.

The logic of this position was confirmed earlier this year, when the European trade association, EucoLight, published the results of a six-nation study which showed consumers are unable to reliably differentiate LED lamps from mercury-containing lamps. It reconfirms the logic of collecting both technologies in the same containers.

However, UK recycling rates are increasing, given that the lamp recycling rate increased from 43.6% in 2015 to 47.5% in 2016. The rate of increase is in part due to the reduction in new lamps being sold, given that LED technologies have a longer lifetime, with hopes that the rate will continue to rise in 2017.

Fluorescent lamps are expensive to collect and recycle. But by understanding how the WEEE regulations work, waste management companies should be able to access a free service, funded by the makers of new lamps.

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