Spot on with LDA’s (Large Domestic Appliances), which have value, but a lot of that so called none availability of old appliances is due to compliance schemes wanting low cost bulk collections from Designated Collection Facilities rather than putting together plans to achieve the collection rates large enough to off-set their members tonnage. The only way to do that is beat the scrap man to door-step collections and that would be even more expensive than buying the evidence.

I am delighted action is being taken on illegal shipments abroad it truly is the ‘elephant in the room’ and is happening because safe disposal cost money.

The number of appliances through AAFTs (Approved Authorised Treatment Facilities) would be hugely helped if trade were allowed to drop electrical goods in to council run DCFs (Designated collection facility). I have never understood why this is an issue. If you did license properly councils could also establish a system for local traders to collect machines for commercial refurbishment which would help re-use, support local businesses and provide high quality low cost appliances within local community. This would also reduce the volume of low cost low lifespan appliances sold.

To put the above in to context I know a guy who runs a private Designated Collection Facility he informs me 13% of what he gets back just works, up to 30% can be fixed for under £30 and if the cost of parts for certain manufacturers machines were not so high, up 80% of what he handles could but fixed and sold. Imaging that on a national basis.

But that would require a coherent nation plan and removal of some to the licenses and stipulations which act as barriers for commercial re-conditioners.

The labelling idea may have potential as it has the advantage that the “sustainability” of a product would be measured up front. The sustainability rating could then be applied to the weight of product placed on the market by the manufacturer. This would result in the producer of high quality but heavier products attracting some relief on their share of disposal costs.

2 It is true that Producer Compliance Schemes – PCS (and their manufacturer clients) only pick up costs for items processed by an Approved Authorised Treatment Facility (AATF). Ironically the complaint is that not enough Large domestic appliances are being made available to Producer Compliance Schemes. The reason of course is that there is substantial scrap value in the items. Now providing the “missing” LDAs are being processed correctly this is not an issue from an environmental perspective – but there are concerns over illegal exports. The Environment Agency (EA) are beginning to crack down and now have a project team specifically looking at illegal exports. They recently recorded their first major success when a site in Essex was raided and several hundred containers were opened for inspection. This resulted in several stop orders and some arrests. The EA strategy is to follow the trail up the line and discover the source of the items with potentially prosecutions to follow.

3 Spot on that Re-use has been very much the poor relation of Re-cycling despite both the Directive and UK Regs requiring re-use as a priority. But there are moves afoot to change things. There are several initiatives running to improve the re-use profile and it is to be hoped that the results of the recent consultations on the UK Regs and a recast EU Directive will give re-use a big boost.

1. IPR (Individual Producer Responsibility)

Had the government stuck to it’s guns and imposed a system on all manufacturers where if you own the brand you are responsible, the waste IPR could have been implemented. However, I am well aware that they would have faced legal challenges from the manufacturers association (AMDEA) relating to forcing members then to take responsibility for WEEE for companies who have now disappeared as part of acquisitions, even though in many case the brand names from the same companies are still used by their new parents.

This means that the system we have is based on paying based on what a manufacturer sells, rather than what they scrap. The basic assumption here is that all machines have the same life-span. Not true; the best measure of likely machine lifespan are the factories own destruction test data, which measure how long a particular model of machine will run before it’s parts start to wear and fail.

In broad terms a ‘VALUE’ machine bought on the high street is built for around 800 cycles, a ‘MID MARKET’ machine around 2000, but some machines are as high as 8000. To achieve this level those manufacturers use higher grades of steel, making them twice as heavy. As WEEE is measured in weight, this means the manufacturers pay 20 times more per machine than those who make the least durable ones.

Apart from being counter productive on WEEE, it begs the question why is destruction test data not a compulsory part of labeling for consumers when they purchase their machine?

2. Only the cost of re-cycling machines which go through government registered re-cyclers (AAFTs) are allocated to the manufacturers for payment.

This means the fewer machines that get re-cycled, the less the manufacturers pay. In 2008 only 40% of the tonnage of Large Domestic Appliances put on the Market found it’s way through the AAFTs (Approved Authorised Treatment Facilities). With cooling appliances this figure was less than 10%. This means that 9 out of 10 fridges that become waste when you purchase a new one simply disappear. Where they go, nobody knows or cares. Good news for manufacturers though as that saves them money – not good news for where they end up though, and it’s worrying given that the Directive expressly forbids the export of electrical waste.

3. Re-use of waste does not count against manufacturers obligations

To reduce their cost, manufacturers can (and some do) run schemes where instead of paying towards overall re-cycling costs they collect old appliances and put them through AAFTs (Approved Authorised Treatment Facilities), this offs their obligations. However, if they refurbish these products rather than re-cycling them this does not count against their obligation. How does this fit with the government’s mantra of REDUCE, RE-USE, RE-RECYCLE?

The spirit of the Directive and the officials who implemented and police it are all acting with the best of intentions, however what is happening on the ground is being influenced more by manufacturer’s desires to keep down cost than their moral obligation to the environment.

After much lobbying by manufacturers it seems to have corrupted into being penalised less for making lighter products. Ironically, Miele could reduce their WEEE costs considerably by substantially reducing the quality of their machines, replacing strong metal with cheap alloy or plastic. Replacing their chrome or stainless steel washing machine doors which virtually never break with cheap plastic ones that do – and so on.

Have I got this wrong? Or is this right and is therefore a little crazy?