TO: EA

CC: DEFRA & WSF Members

Published as Open Letter on Linked In

 Dear Environment Agency

 We write in response to the decision by the Environment Agency on 21 March to increase the subsistence fee charges for UK producers and the introduction of a new subsistence FEE for PCS. The whole process has started from a position that the existing subsistence fee mechanism was somehow fair. We write to express WEEE Light’s disappointment and respectfully request you re-think the decision.

 WEEE Light Ltd raised serious concerns to the WSF, EA and DEFRA prior to the deadline for submission of responses, which resulted in 11 other schemes agreeing that, the WSF submission was fundamentally flawed. Despite this the WSF solution was submitted referencing that 11 opposed the response to EA with no further narrative as to why. (Interestingly the respondents on behalf of Recolight and Ecosurety in the Lets Recycle article of 26 March are amongst the authors of the WSF submission). The EA has made the same fundamental flaws when forming your policy. 

 We informed the WSF, EA and DEFRA (during the last WSF meeting 7 February) of WEEE Light’s disappointment that the EA consultation, given the emphasis you place on the view of the WSF, would miss the opportunity to create a structure which was fair to all UK businesses. It is ridiculous to image that a company with an £3bn turnover associated to placing EEE in the UK would have a problem with paying the new subsistence fee of £750. In contrast a company with a £1m turnover with only £30K of this income associated to placing EEE in the UK will have to pay the same amount as its £3bn turnover competitor. Furthermore the introduction of a flat FEE for PCS without regard to its size or indeed its WEEE obligations creates exactly the same injustice as that we see for Producers & AATF’s.

 WEEE Light Ltd fully appreciates the challenges the EA have in policing EEE and WEEE compliance in the UK. A fair solution, which was submitted as part of our response to the consultation, is a mechanism linked to 1) a companies EEE placed, 2) a PCS’s WEEE obligations and, 3) an AATF’s WEEE Collection Volumes.

 We believe the EA needs to go back to its drawing board and consider the key factors especially given that the mechanism for producer subsistence has always been unfair.

 Key facts:

Polluters pay in the UK via producers and their schemes in an open marketplace

Today there is no government narrative that objects to the number of producers, PCS and/or AATF

The UK systems only true common denominator is a producers EEE placed weight by category which is exercised through a PCS scheme obligation and collected by AATFs

Fixed agency fees for Producers calculated against turnover is clearly not a fair; nor indeed a sustainable charging mechanism for smaller producers

Fixed agency fees as a one charge fits all for PCS is clearly not fair; nor indeed a sustainable charging mechanism for smaller PCS

The real opportunity missed by the EA in the consultation process was to recover the funds required by the agency to police a compliant system in the UK in a fair, balanced and level playing field for all. We suggest a starting point for re-consideration would be:

Producers pay per tonne of EEE Placed against the budget set by the agency = level playing field for all

PCS pay per tonne of EEE Obligation against the budget set by the agency = level playing field for all

AATF pay per tonne reported against the budget set by the agency = level playing field for all

We look forward to hearing back from you without undue delay and hope any arguments against our proposal for a re-think would be strong enough to explain why:

 a producer placing significantly less EEE subsidises producers placing more

PCS with significantly less EEE obligation subsidises the PCS’s with more obligation

an AATF collecting significantly less volume subsidises AATF’s collecting more volume

 

Yours faithfully

Vincent F Eckerman

Director

WEEE Light Ltd

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