IEMA responds to the UK and Devolved Governments’ Consultation on Reforming the Producer Responsibility System for Waste Electrical and Electronic Equipment

Plans to reform the Waste Electrical and Electronic Equipment (WEEE) Producer Responsibility System across the UK were outlined in December 2023 to implement an Extended Producer Responsibility (EPR) system aligned with the polluter pays principle. The proposed framework emphasises the need for clear outcomes, full net cost coverage by producers, incentives for sustainable design and production, and making it easy for consumers to play their part.

IEMA consulted with Circular Economy Network members to gain insights and identify gaps in the proposals.

The outcome was several recommendations that IEMA believes would strengthen the proposals and help support the transition to a circular economy.

Overall, IEMA supports the proposals that producers and distributors either run their own take-back service or finance collections of large and small EEE and WEEE from households. However, to work towards sustainable production and consumption, a standardised approach is needed for all producers and distributors, whether they are retailers, online marketplaces or fulfilment warehouses. All electronic and electrical equipment (EEE) products placed on the market should be included in the reform.

One of the core principles of a circular economy is to retain materials and products at their highest value whilst reducing environmental impact. To achieve better rates of reuse and repair of EEE and WEEE, the government should adopt the R-Ladder instead of the traditional waste hierarchy as this prioritises mechanisms to rethink product design at the first instance and keep products in their highest value for longer, such as, repair, remanufacture and reuse.

Kerbside collections present risks such as damage, theft, or environmental harm, requiring mitigation measures. It is important that collection of items does not result in further damage or destruction.

Improved data collection is also essential to gauge the quantity and categories of EEE put on the market, enabling informed decisions for closed-loop interventions and resource allocation.

Effective governance of the new EPR scheme is paramount and demands proportional representation, incorporating local authorities, reuse, and repair organisations. Diversity ensures that decisions are made with a broader understanding of the implications and that the needs of all involved parties are considered and allows for the foundations of transparent cost apportionment being agreed, transparent data, and combining expertise and resources to drive innovation and help unlock the circular economy.

In summary, the proposed reforms aim to establish a robust EPR system aligned with sustainable principles. However, IEMA recommends further action is needed to boost resource efficiency, risk mitigation, data transparency, and collaborative governance. These measures collectively will help the transition to a circular economy while addressing environmental challenges associated with electronic waste management.

Download IEMA's full response here.