The recent consultation in which Amdea was involved was focused on recycling of batteries. Details of the consultation can be found on the BERR (the Department for Business) website, but it is interesting to note that of the 128 organisations that responded, 27 were from producers, 25 were from trade associations and just six were from retailers. The UK decided to implement the EU Directive on batteries as two Statutory Instruments, the first that affects just producers is already in force. The second that also affects retailers, the Waste Batteries and Accumulators Regulations 2009 will, subject to Parliamentary approval, come into force on 5 May 2009. These Regulations require retailers to take back batteries from 1 February 2010, although there are exemptions for small stores.

There is a lot of ongoing work and among the projects underway are Directives aimed at protecting the environment, namely the WEEE and RoHS Directives.

Just to remind you, the WEEE Directive concerns recycling and reuse of electrical and electronic equipment (including domestic appliances), while RoHS is about restricting the use of hazardous substances within products.

The European Commission has made proposals to revise both Directives and these are under consideration in both the European Parliament and the Council of Ministers. As part of the process of establishing the view of the UK within the Council of Ministers, BERR launched a single consultation covering both Commission's proposals.

AMDEA in turn has asked its members for their views. The provisions contained in the RoHS Directive are of limited interest to retailers and distributors. It is producers who will have to check for the presence of chemicals etc in their product, though retailers who import directly will find they have certain obligations.

The WEEE Directive is of much broader interest and there are a number of issues raised by the EU Commission's proposals. To start with, there is the ambitious target of a minimum collection rate for WEEE of 65% for an aggregate of all WEEE. The existing rate (for Consumer WEEE, the figures for Business WEEE are lower still) within the UK for 2006-2007 was around 23%, while the 2007-2008 figure was around 30%. Hence it seems unlikely that the Commission's target can be achieved within the timeframe proposed.

Under the system established by the WEEE Regulations in the UK, domestic WEEE is taken to Designated Collection Facilities (DCFs) by home owners or by retailers who offer this service. Producers/manufacturers of WEEE are obliged to register with a Producer Compliance Scheme (PCS). Through this, producers pay for their obligations under the WEEE Directive.

However, most DCFs collect waste of all types and there is no obligation on these to pass WEEE collected to the PCSs. The result has been that certain types of product (eg with a high metal content) can end up being treated as scrap metal rather than WEEE and in some cases is being shipped abroad.

That WEEE is not being treated correctly is known to the European Commission, but their solution seems to be to pass responsibility onto producers rather than to require local authorities to give the collected WEEE to PCSs.

We also have concerns about the emphasis on re-use targets in the Commission proposals. Of course, re-use can be a good thing, for instance if it means extending the life of a relatively new working product that has only been swapped for fashion or aesthetic reasons. But re-using old products that consume far more electricity and water than a modern equivalent (as with washing machines) does not result in an environmental benefit.

In this context we welcomed the recent open letter from the CBI to the Chancellor Alistair Darling which placed early replacement of domestic appliances alongside "scrappage policy" for the motor industry. AMDEA has worked closely with the CBI on energy and climate-related issues and it is good to see the results of this work being reflected in strong representations to the Government.

There aren't always instant solutions, but consultation will continue to play an important part in communicating the views of our industry to political decision-takers.

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