International Review of Waste Management Policy - Department of ...

20.10 Lessons Learned
Administrative Administrative burden
burden
The administrative burden on individual businesses should be considered when
designing producer responsibility systems – the need for reporting to counteract freeriding
is acknowledged, but the requirements should be balanced and should be
considered according to the product in question and the consistency of the markets
for that product. The use of collective compliance schemes reduces the individual
burdens placed on businesses. In addition, the development of and investment in IT
infrastructure would help reduce the economic impact of reporting requirements,
though this possibility is typically unaffordable for SMEs.
According to the UNU report, there are currently large differences in the number of
registered producers according to MS within the EU, resulting from differences in the
‘definition’ of producers, the role of distributors and the impact of SME awareness of
their obligations and the need to be registered. Industry across Europe has raised the
issue of ‘free-riding’, particularly regarding SMEs and their lack of awareness. In
addition, different obligations to register B2B compared to B2C has led to some
producers registering their products only as B2B, even when placing the product on a
B2C channel (especially where no clear definitions of B2B compared to B2C exits) to
avoid these obligations.
Differing reporting requirements (see Table 20-1) also place differing financial
burdens on the overall WEEE system. The higher the frequency of reporting, the
higher the number of hours required to report and, consequently, the higher the
economic and administrative burdens. The majority of registered producers see the
need for reporting (particularly to try and track free-riding), but a high percentage of
stakeholders are experiencing a burden in carrying out such reporting. If financial
obligations are to be decided according to amounts of products placed on the
markets, the frequency of reporting should also be product-specific as some markets
fluctuate throughout the year. In addition, varying definitions of B2B compared to B2C
currently determine different financial obligations in different countries.
The proposed revision to the EU WEEE Directive includes the requirement to
harmonise both the registration and reporting obligations for producers between the
national producer registers, including making the registers inter-operational (i.e.
between countries). In addition, clarification of the distinction between B2B and B2C
WEEE, through a comitology procedure, will further clarify which products fall under
the legislation and the obligations that apply to different EEE producers.
Awareness
Awareness
There is a need to increase the awareness of WEEE regulations for both businesses
(particularly SMEs) and the public. Low WEEE return rates are partly the result of a
lack of awareness and sometimes also a willingness of the consumer/ end-user to
actively participate in WEEE take-back systems. It may also help if consumers were to
know what they are paying for when they buy a product (e.g. visible fees) to ensure
their contribution to take-back system performances. A survey undertaken of more
than 2,000 people in the UK by an electrical retailer (Comet) found that only 2% of
people knew about the WEEE Directive. 71 % had no idea what the logo that is
displayed on new electrical products to show it should be recycled actually meant
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International Review of Waste Policy: Annexes