The Environment Agency has released guidance on what data should be included by producers of EEE and batteries in the UK.
It seeks to clear-up confusion over the definition of "Placed on the Market".
Producers of EEE and batteries are required to report the weight of the products they placed on the UK market. There has previously been some confusion about when products are deemed to be "Placed on the Market", as the term is not defined within either regulation. Many producers have used sales information to approximate this figure. However, the new guidance explains that all products entering the UK and made available for sale to UK customers, regardless of the actual end destination, should be reported under the regulations.
Products that arrive in the UK and are subsequently exported may only be omitted if it is known at the time of import that they will be exported or there is evidence to suggest they were always destined for export (instruction booklets, non-UK voltages, specifications, packaging). Only battery producers are invited to voluntarily provide data to their compliance scheme regarding the amount of products sold to customers outside the UK that were deemed to be placed on the UK market. There is no provision for export reporting in WEEE.
We welcome this information from the Environment Agency. However, we do not feel that producers should be obligated to recycle batteries that do not end up in the UK waste stream. We have fed back member opinion to lobby government to make changes, as part of our own feedback, and through contributions to the stakeholder groups we actively participate in. In the next revision of the regulations, we hope to see exported products discounted from producers' obligation in a similar way to that which currently exists for the packaging regulations.
Head of policy
Having gained a wealth of experience in regulatory affairs, waste issues and secondary commodity market analysis, Robbie uses his skills internally as an operational board member and externally to influence legislation change as head of policy. He is responsible for liaising with government, regulators and industry organisations to articulate complex views and interests and to provide high-level policy expertise, industry insight and market analysis to our members.
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