As readers will be aware, in the UK LED-based lighting products fall under the WEEE regulations which govern how such products must be treated when they reach end-of-life (WEEE stands for Waste Electrical and Electronic Equipment).
The WEEE Directive has recently been undergoing a “recast” to clarify some specifics which have, in the past, been open to interpretation; for example, LED lamps are now specifically named in the Directive, avoiding the current confusion of such products being in-scope in some countries, and out-of-scope in others.
One of the main changes outlined in the recast Directive revolves around targets. Higher targets for WEEE collections have been set out; currently, the target is 4kg of WEEE per head of population but in the new Directive, the target rises (after four years) to 45% of EEE put on market, and then to 65% after seven years.
Achievement of these targets will be challenging, but LED companies need to play their part by ensuring they are members of a Producer Compliance Scheme like Recolight. Registration with a Compliance scheme is a legal requirement that all producers and importers need to be aware of, in order to avoid enforcement action being taken against them by the Environment Agency.
In the UK, the Environment Agency already classes LEDs as in-scope, so companies importing, producing, or own-branding LED- or OLED-based lamps should already be complying with the WEEE regulations. For many UK companies, who only import a small quantity of LEDs or other lamps, complying with the WEEE Regulations may seem like a burden. However, good compliance schemes can work with you to ensure this isn’t the case by making compliance as simple as possible.
The Environment Agency has recently announced that significant changes have been made to the way the WEEE Regulations are enforced in the UK. The clarification means that companies (producers) may no longer pass financial responsibility for recycling onto the business end-user when their products are sold via an intermediary (such as a wholesaler).
In the past, they did this by using regulation 9.2 of the WEEE Regulations. This approach has been used by many businesses to comply with the WEEE Regulations. In the lighting industry, the overwhelming majority of lamps are sold via an intermediary where there is no contractual relationship between the producer and the user. Now, regulation 9.2 may therefore not be used in such situations, and Recolight and its producer members do not use regulation 9.2.
In light of these changes to the application of the WEEE Regulations, we would advise end users purchasing new lighting products to ensure that the producer is not attempting to use regulation 9.2 to pass on the cost of recycling to them, unless they have a direct contractual relationship with the producer.
In light of increased demand and the limitations of primary source materials essential for the production of LED- and OLED-based lighting, it will be more important than ever to be able to recycle and reuse existing materials.
Recolight has seen a continued growth in its membership and many of the new members are LED producers and/or importers.
Case study
LED Eco Lights, based in Camberley in Surrey, became a Recolight member in 2011. The manufacturer of Goodlight-branded products, LED Eco Lights has been operating since 2006, focusing on providing LED replacements for traditional lamps and lighting. A UK-based team design and engineer the range of products, with assembly taking place in the Far East. This set-up gives the company full control over the design and manufacturing process, as well as the ability to deliver rapid prototyping of new products in short timescales.
LED Eco Lights has always complied with the WEEE Regulations. Saima Shafi, Sales & Marketing Director, said; “In the beginning, complying was something that proved quite time consuming, but it became very simple quite quickly. We joined Recolight because we felt it very important to be able to provide a national service to our customers for free lamp recycling, and something they could access with ease. Recolight’s dedicated lamp-focused service is completely in line with our needs, so we can meet compliance requirements for both business and residential customers, which is really important for us.”
Recolight was established by the lighting industry, and as such it understands lamp producers’ needs. Producer members are kept up-to-date changes in legislation and obligations, so they can focus on driving their businesses forward, launching new products to meet customer demand, and developing exciting new solutions, while end users can make use of Recolight’s free lamp collection and recycling services.
