Review Of The Producer Responsibility Initiative Model In ... - Repak

If this examination concludes that, after discharging the requirements for all outstanding
end-of-life treatment of historic WEEE, a surplus of funds still remains, then
recommendations shall be provided on how to utilise the remaining funds in a way which
is in line with the legislative requirements and is reflective and supportive of this
Department’s environmental policies and the Waste Framework Directive.
Ireland’s two compliance schemes for WEEE (WEEE Ireland and ERP Ireland) currently
operate under an approval from DECLG. Certain inter-scheme balancing arrangements
also operate pursuant to a voluntary agreement. Any barriers to transfer of producers
between the compliance schemes should be identified. Recommendations shall be
provided for a regime whereby producers can readily switch between the two compliance
schemes without losing rights or entitlements. This switching regime should be simple,
straight forward and administratively easy for the producers. It should also involve an
arrangement as to how producers can bring the funds that they paid for historic WEEE
with them as well as analysis of the historic movements of producers between the
schemes and the effect of the non-transfer of funds will be required to fund such
considerations.
In late 2010 and throughout 2011, as a consequence of the overall problem of metal theft
across Europe, we have seen increasing misappropriation of WEEE, whereby quantities
of WEEE flow outside legal channels, commonly known as “WEEE leakage”. This has
become a serious problem and we need further recommendations as to how we combat
this leakage and retain the flow of WEEE within the legal channels. These
recommendations would have the dual aims of (i) contributing to Ireland meeting the
targets which will be contained in the newly recast EU WEEE Directive and (ii) ensuring
that WEEE is diverted to channels which will ensure its proper end-of-life treatment while
ensuring that legitimate operators are not put at a competitive disadvantage.
Since the implementation of the WEEE Directive in Ireland, we have maintained a regime
of vEMCs or visible costs. This regime of visible costs expires in early 2013 but Member
States, under the recast WEEE Directive may continue to show environmental costs. We
need an examination of the benefits and disadvantages of retaining such a structure in the
future, e.g. what is the perception of consumers of these fees and do they play an
important part in terms of awareness-raising for consumers
We also require recommendations as to how to boost the collection rates for WEEE in
Ireland. The study should examine examples of best practice of WEEE collection in
Europe and see if there are systems which could be adopted for use here. In examining
best practice models, we should also examine what specific measures can be taken to
incentivise the various participants in the WEEE collection chain in order that we can
maximise the collection of WEEE. We also require an analysis of the options in the recast
WEEE Directive for Ireland in regard to the WEEE placed on the market approach versus
the WEEE Generated approach.
Advice should be provided on a reuse protocol and how an ongoing scheme of reuse and
preparing for reuse can be implemented for the WEEE waste stream having regard to the
legislative requirements, e.g. should reuse be led by separate dedicated compliance
scheme(s) or through the existing WEEE compliance schemes Also, how can the
concept of reuse be best communicated to the general public and endeavours of existing
reuse organisations and commercial companies be most appropriately integrated into the
reuse system. Finally, as part of this reuse system, we need to develop a methodology
which allows the Environmental Protection Agency (EPA) to capture the data on WEEE
prepared for reuse which is necessary for statistical returns to the European Commission.
In common with certain other waste streams where the position regarding the compliance
schemes and their inter-relationship has evolved through a network of producer
responsibility agreements, it is now necessary to review these structures to see if there is
a need for further enhancement in order to cater for the emerging regulatory regime. In
particular the operation of the existing producer responsibility agreements should be
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