Members update on WEEE Group B2B Compliance scheme lobby

A quick re-cap of the legislation was given, detailing the responsibilities of all producers; both B2B and B2C.  It was explained that the majority of CEA members are deemed Business to Business.

Currently, there are two WEEE Compliance Schemes in operation in Ireland: - European Recycling Platform (ERP) and WEEE Ireland. Currently, these companies accept ‘Producers' into membership under certain terms and conditions. These Producers, as compliant members, can defer the finance and collection obligations as a B2C Producer, to the compliance scheme.

However, there is no B2B compliance scheme in operation at present, although an application for an a fully accredited B2B compliance scheme was made, the Department of Environment, Heritage & Local Government (DoEHLG) have not approved any scheme.

The CEA, through IBEC, met with DoEHLG to lobby them on gaining approval, 'in principle' for a collective group compliance scheme for the industry on B2B.  The CEA outlined the clear advantages to the Department and industries such as the CEA, from having a B2B group scheme in place, as:

· Providing consistency in WEEE compliance across industry sectors;

· Addressing financial penalties that could be imposed under the legislation;

· Providing clarity that the waste stream of members is B2B and can be treated as such; and

· Reducing individual company administration burden through a group scheme.

The CEA also gained the support of the Electrical Industries Federation of Ireland (EIFI), and the Irish Engineering Enterprises Federation (IEEF).

Members have been urged to continue gathering data for the Waste Management Plan. CEA and IBEC have been given the undertaking by the WEEE Register Society that no prosecutions will be made on CEA members in the short-term.  CEA gave the undertaking to the Department that a concerted effort would be made by members to satisfy compliance by end of January 2008.

The CEA believe members have two options:

1. Self Comply by:

Passing on the obligation for WEEE contractually to the customer; or

Netotiate better recycling rates by working together (could be a forerunner to a scheme)

2.  To wait for a B2B compliance shceme to be put in place & then join it.

CEA are currently arranging a members briefing session, faciliated by the EPA, WEEE Register Society and the WEEE Blackbox, which will take place in January 2008 (provisional date of 16 January has been set).  This briefing session will inform and educate members on how to complete a Waste Management Plan, Scoping issues and submitting data to the blackbox.

CEA are also in touch with B2B Compliance in the UK, to find out more about how there compliance scheme came into operation. The CEA believe the creating of a B2B scheme by the catering industry alone would not be viable, however it may be with the support from other industries.

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