Post by RajSaber » Mon Dec 09, 2019 10:05 pm

First and foremost, my apologies if this post isn't deemed relevent by some members of the forum.

Please kindly understand that this issue is of great importance to UK business that sell Electrical products especially in the current political climate.

For those of you who are aware, the UK currently operates under the WEE (Waste Electrical and Electronic Equipment) regulation enforced by the EU.

The EU WEEE Directive 2012 regulates the management of electrical and electronic waste. It is applied in the UK by the Waste Electrical and Electronic Equipment (WEEE) Regulations 2013.

The WEEE Regulations also place an obligation on distributors to offer to consumers a take-back system where WEEE items can be disposed of free of charge.

There are two types of take-back systems, and distributors of EEE items must offer one of these schemes to their customers.

-Take-Back Systems

1) Free in-store take-back scheme where distributors accept WEEE items from customers purchasing equivalent new items.
2) Distributor take-back scheme where consumers can dispose of WEEE items free of charge at designated collection facilities.

In the UK, Valpak (https://dts.valpak.co.uk/) has provided a DTS (Distributor Take Back scheme) giving UK retailers who sell Electrical products the option to pay an annual fee to support local recycling fee (as per business output). This gives the Distributing business the choice to opt out of providing "free in store take back".

The current DTS scheme (phase 4) is coming to an end on the 31st December 2019. Valpak has submitted a proposal to DEFRA (Department for Environment Food and Rural Affairs) for phase 5 of the DTS which would be an interim for 2 years (1st Jan 2020 – 31st Dec 2021), while the Government undertakes a review of the UK WEEE regulations.

If the DTS is not approved for renewal, the default position under the current WEEE regulations requires all distributors of EEE to offer take-back to their customers of B2C (inc. dual-use) equipment on a one-for-one like-for-like basis at point of sale from 1st January 2020.

This means that in the event that the DTS isn't renewed, UK distributors of Electrical goods will have to take in unwanted goods on a like for like basis.

I (and I'm sure many others would agree) that the taking back of goods that weren't purchased from a retailer, having to facilitate their collection and transfer to designated recycling centres is unfair to small retailers and completly removes all responsibility from the consumer.

Many small online retailers selling Electrical products may be operating from private residents or homes, I personally wouldn't want to have to collect like for like unwanted goods or have random strangers drop them off at my residence.

The renewal of the DTS scheme depends on the Secretary of State for the Environment providing confirmation. Due to the General Election on 12th December 2019, it is unlikely that the current Secretary of State for the Environment will confirm if the DTS will continue prior to this date. We will, unfortunately, likely have to wait until the new Secretary of State is appointed following the results of the election.

Ideally, it would be best especially for small distributors of Electricals, if the DTS scheme continues. In the unfortunate event it isn't implemented further - I would propose a petition to request an opt out service provided as an alternative to "in store take back".

As a retailer of Electrical products, I agree that such business should financially support local recycling projects as per their turnover/size. But the "taking back" of goods in store is in my opinion unfair to small retailers of such goods.

I'm considering starting a petition, but need to know if other retailers would be willing to help by signing if this were to occur?

Kind regards

Raj

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