J
James
If you are a small producer affected by the WEEE regulations you may be
concerned enough to read this. Otherwise please excuse the post - it's
rather long by necessity, but isn't intended to be spam.
The WEEE regulations discourage new startups and penalise small businesses
¡V without environmental benefit. The problem is caused by the UK
legislation, which goes well beyond the requirements of the European WEEE
Directive.
The only effect on producers of small amounts of equipment is to take
substantial sums of money (ie hundreds of pounds per year) from them, and
to oblige them to supply unusable data about their production.
I made small quantities of equipment for other businesses during more than
thirty years. No business was ever likely to ask me to take back equipment
for disposal - they all had, and have, their own industrial systems of
waste disposal. So the waste disposal is paid for, and implemented, by the
buyer of the equipment. Both the WEEE Directive and UK law rightly allow
this system to continue.
No matter how much you exaggerate the numbers, the total amount made by
small producers can never come near the threshold of measurement error in
the total (see addendum below).
The burden on small producers is out of all proportion to the quantity of
equipment they produce. It discourages people with a good idea from trying
to start making anything electrical, and sends a clear message to everyone
"Your Government will take a levy from you if you try to manufacture
something".
I suggest that the Government should no longer require producers making
less than one tonne (five tonnes would be more rational) to register,
report, or pay. The European WEEE Directive doesn't require it - it's an
addition of the UK Statutory Instruments.
If you or your employer are unfairly penalised by the legislation, you can
make your views known for a limited time on the web site of the Department
for Business Innovation and skills at
http://www.redtapechallenge.cabinetoffice.gov.uk/environment/waste/ and by
email to redtapechallenge(at)bis.gsi.gov.uk
If you feel concerned enough to do this it would probably help your case to
write also to your own MP. You can find your MP's contact details at
http://findyourmp.parliament.uk/
FM
Addendum - quantities produced
The total quantity of equipment made by all small producers is orders of
magnitude below the threshold of measurement error in the total of
equipment made. The Environment Agency's own data shows more that 1.5
million tonnes of electrical equipment made in 2009, with a little over
5,500 companies registered - an average of more than 270 tonnes per
company. Small producers, making a few tens of kilograms each, can never
come near the measurement error in the total, even if the number of small
producers is grossly exaggerated. To take an exaggerated example, if almost
all the companies registered were small producers, and each was making
(again exaggerated) one tonne (ie 1000kg) each, the total would be 5,500
tonnes, which is less that one-third of one percent of the total 1.5
million tonnes. So the Environment Agency is spending a lot of time and
money collecting data which is of no possible use.
concerned enough to read this. Otherwise please excuse the post - it's
rather long by necessity, but isn't intended to be spam.
The WEEE regulations discourage new startups and penalise small businesses
¡V without environmental benefit. The problem is caused by the UK
legislation, which goes well beyond the requirements of the European WEEE
Directive.
The only effect on producers of small amounts of equipment is to take
substantial sums of money (ie hundreds of pounds per year) from them, and
to oblige them to supply unusable data about their production.
I made small quantities of equipment for other businesses during more than
thirty years. No business was ever likely to ask me to take back equipment
for disposal - they all had, and have, their own industrial systems of
waste disposal. So the waste disposal is paid for, and implemented, by the
buyer of the equipment. Both the WEEE Directive and UK law rightly allow
this system to continue.
No matter how much you exaggerate the numbers, the total amount made by
small producers can never come near the threshold of measurement error in
the total (see addendum below).
The burden on small producers is out of all proportion to the quantity of
equipment they produce. It discourages people with a good idea from trying
to start making anything electrical, and sends a clear message to everyone
"Your Government will take a levy from you if you try to manufacture
something".
I suggest that the Government should no longer require producers making
less than one tonne (five tonnes would be more rational) to register,
report, or pay. The European WEEE Directive doesn't require it - it's an
addition of the UK Statutory Instruments.
If you or your employer are unfairly penalised by the legislation, you can
make your views known for a limited time on the web site of the Department
for Business Innovation and skills at
http://www.redtapechallenge.cabinetoffice.gov.uk/environment/waste/ and by
email to redtapechallenge(at)bis.gsi.gov.uk
If you feel concerned enough to do this it would probably help your case to
write also to your own MP. You can find your MP's contact details at
http://findyourmp.parliament.uk/
FM
Addendum - quantities produced
The total quantity of equipment made by all small producers is orders of
magnitude below the threshold of measurement error in the total of
equipment made. The Environment Agency's own data shows more that 1.5
million tonnes of electrical equipment made in 2009, with a little over
5,500 companies registered - an average of more than 270 tonnes per
company. Small producers, making a few tens of kilograms each, can never
come near the measurement error in the total, even if the number of small
producers is grossly exaggerated. To take an exaggerated example, if almost
all the companies registered were small producers, and each was making
(again exaggerated) one tonne (ie 1000kg) each, the total would be 5,500
tonnes, which is less that one-third of one percent of the total 1.5
million tonnes. So the Environment Agency is spending a lot of time and
money collecting data which is of no possible use.
