Summary of responses and government response

Question 1

Introduction

Accepted Answer

This is a government response and summary of the responses to the consultation on reforming the producer responsibility system for waste electricals.

This was a joint consultation between the previous UK government, Scottish government, Welsh Government and the Department of Agriculture Environment and Rural Affairs in Northern Ireland (DAERA). It was held between 28 December 2023 and 7 March 2024.

The consultation sought views on:

introducing a producer financed household collection system for small and large items of waste electrical and electronic equipment (WEEE)
enhancing retailer obligations to provide a free collection on delivery service for large appliances, enhanced in store takeback provisions and strengthened customer communication obligations
designating online marketplaces as a new type of producer and giving them the same obligations as UK based manufacturers and importers in respect of registration, data reporting and sharing the cost of collection and treatment of equipment that is placed on the UK market when it becomes waste
creating a new category of equipment for vapes to ensure that the costs of collecting and treating these items are borne solely on those who place them on the market
establishing a new WEEE scheme administrator to undertake certain functions connected to the implementation of the WEEE system, including the management of a new household collection service should that be implemented post-consultation

Question 2

Government response

Accepted Answer

The UK government, Scottish government, Welsh Government and DAERA are grateful for the responses received to this consultation.

We are continuing to consider all proposals set out in the consultation and the associated call for evidence and will set out our response to those proposals in 2025.

In the immediate term we will work together to bring forward the following measures to address unfairness in the Waste Electrical and Electronic Equipment Regulations 2013 related to the distribution of producer responsibility costs.

A new category for vapes

We will amend the current regulations to require producers of vapes, vape related products that are sold separately (for example, replacement coils) and other e-cigarette style products to report the weight of products placed on the UK market in a new category of equipment. 

Vapes are currently reported under category 7 of the regulations which covers toys, leisure and sports equipment.

Regulations will be introduced in 2025 with changes to the reporting requirements so that a separate collection target for the new category can be set by the Secretary of State for Defra from 2026.  WEEE reporting obligations will also be amended to reflect the introduction of the new category. 

New obligations for online market places

We will amend the current regulations to place new obligations on online market places so that they contribute to the cost of collection, treatment, re-use, and recycling of WEEE in line with those obligations that currently apply to companies defined as producers within the existing regulations.

The new requirements will apply to online marketplaces only in respect of equipment placed on the UK market by their overseas based sellers. 

The regulations will be amended in 2025 to include a requirement on online marketplaces to join an approved WEEE compliance scheme. They will pay a registration fee to the relevant regulator and report data, via their compliance scheme, on the weight of equipment placed on the UK market by their overseas sellers in each of the WEEE categories of equipment.  This will include reporting data under the proposed new category for vapes.

Transitional reporting obligations will be introduced in 2025 to ensure that online marketplaces are financially obligated in respect of sales by their overseas sellers in 2026. Obligations will be in line with those placed on businesses defined in the regulations as producers.

New charges will be introduced to cover the costs of compliance monitoring of registered online marketplaces by the Environment Agency, Scottish Environmental Protection Agency, Natural Resources Wales and DAERA. The Environment Agency intends to undertake a targeted consultation covering their proposed charging regime.  

A shared priority to drive a circular economy

More widely we are committed to a shared priority to drive a circular economy across each of the 4 nations. Such an approach can stimulate economic growth, protect the environment and create social value.

The commitment to the circular economy is deeply embedded in respective strategies of the Scottish and Welsh governments, and DAERA:

Scotland: Circular economy and waste route map to 2030
Wales: Beyond Recycling
Northern Ireland: draft Circular Economy Strategy for Northern Ireland

The UK government will publish a circular economy strategy for England in 2025. It has formed a Circular Economy Taskforce, comprising members from industry, academia, and civil society from across the UK to lead the development of that strategy.

Discussions between the 4 nations on policy development on material resources and waste related to electrical and electric equipment will continue with the responses to the consultation and call for evidence informing those discussions. The UK government, Scottish government, Welsh Government and DAERA will set out plans for wider reforms that reflect their strategic priorities in the drive towards a circular economy across the UK in 2025.

Question 3

Summary of responses

Accepted Answer

We received a total of 320 separate responses. Not all responses considered all questions. We received responses from a range of stakeholders, as set out in the table below.

Table 1: Responses by organisation type

Organisation type	Number of responses
Local government	99
Electronic producer	45
Individual (not representing an organisation)	45
Distributor (including online marketplace)	27
Trade body or other business representative organisation	20
Other	14
Charity or social enterprise	12
Waste management company	12
Producer compliance scheme	11
Community group	9
Consultancy	7
Approved authorised treatment facility (AATF)	6
Re-use or repair operator	5
Non-governmental organisation	4
Academic or research	3
Unknown	1
Total	320

We received 3 responses shortly after the consultation closed. We have considered these alongside the other consultation responses, although they are not included in the statistical summaries, including the table above.

Chapter 1: Increasing household collections of WEEE

This section of the consultation asked questions around the establishment of a producer funded household collection system for small and large items of Waste Electrical and Electronic Equipment (WEEE).

Question 6: Do you agree or disagree that producers (and distributors that do not provide their own take-back services for electric and electronic goods) should finance collections of small WEEE (for example, toasters, small toys and tools), from households?

Question 7: Please provide any evidence you have to support your answer to question 6.

64% agreed that this proposal would decrease levels of WEEE in residual and fly-tipped waste and drive up levels of WEEE for recycling. Some evidence was provided to suggest that this would reduce risk of battery fires.

9% disagreed with this proposal.

27% of respondents, largely producers, were unsure and recommended trials to test the feasibility and effectiveness of the service.

Question 8: Recognising the need to balance frequency of service with efficiency, what frequency should a WEEE collection round be provided?

Question 9: Please provide any evidence you have to support your answer to question 8.

47% of respondents favoured monthly collections, 25% an on demand service, 21% fortnightly and 8% weekly collection rounds. Respondents did not provide evidence to support their answers.

Question 10: Would there be benefit in providing for different arrangements to apply in different areas according to circumstances, for example, on demand in some areas and regular collection round in others? Please provide any evidence you have to support your answer. 

Most respondents acknowledged that there would be benefit in providing for different collection arrangements in different areas, with many noting that urban collection rounds would need to be more frequent than those in more rural areas.

Question 11: What should items qualifying for this service be defined by: weight or dimension?

The majority of respondents answered that items qualifying for this service should be defined by the dimension of the product.

A minority answered that both could potentially be used as qualifying criteria.

Question 12: Please specify any products that, due to their properties, should be excluded from the small WEEE household collection service.

Many respondents, including a core of lamp producers, said that lamps should be excluded from household collections due to their fragility and the materials they contain. It was also suggested that householders should remove batteries from their equipment and put these into a separate container, along with items containing integrated batteries like disposable vapes.

Question 13: For any products listed in response to question 12, what measures should be put in place to drive up levels of their separate collection to minimise disposal in residual waste? 

For lamps it was suggested that these items should instead be collected in store by retailers who sell them.

Question 14: Do you agree or disagree that producers (and distributors that do not provide their own take-back services) should finance collection of large WEEE?

Question 15: Please provide any evidence you have to support your answer to question 14.

68% of respondents agreed that producers should finance the collection of large WEEE and that this is in line with the principle of extended producer responsibility. It was noted that not everyone has access to a household waste recycling centre and that this measure would reduce fly-tipping. 19% of respondents disagreed and 13% were unsure.

Question 16: Do you agree or disagree that a producer-led scheme administrator, approved by government, is best placed to determine the most practical and efficient delivery mechanism to manage producer obligations to finance small and large WEEE collections from households?

Question 17: Please provide any evidence you have to support your answer to question 16.

44% of respondents agreed, arguing that producers should have control over the scheme administrator to ensure they manage and control costs in meeting their statutory obligations. It was also noted that it would be beneficial for all functions to be centralised.

39% of respondents were unsure and 17% disagreed. Many of these indicated that more clarity would be needed as to the scheme administrator role and that wider representation beyond producers would be necessary to ensure a balanced approach beyond that of minimising costs.

Question 18: Do you agree or disagree that the most efficient and cost-effective delivery of the obligation to provide a regular household collection service for small WEEE and bulky waste collections for large WEEE is likely to be achieved through partnerships between a scheme administrator and local authorities and their waste management partners?

Question 19: Please provide any evidence you have to support your answer to question 18.

48% of respondents agreed that local authorities are best placed to deliver this service. 40% of respondents were unsure, with many producers (and others) suggesting industry funded trials with local authorities to better establish the costs of delivering a successful service and the likely level of collections that would result.

Local authorities thou8ght that all costs incurred as possible delivery partners should be financed by producers. Also, some local authorities may not have the capacity to take on this role, suggesting other service providers may be required in some areas.

12% of respondents disagreed.

Question 20: If you answered agree to question 16, what, if any, safeguards might be necessary to ensure costs incurred by producers in meeting the WEEE household collection obligation are reflective of the actual costs of delivery through their service partners? 

Some of the safeguards mentioned included the scheme administrator to establish a test of efficient and effective service relative to profile of each local authority and for disputes to be settled by an independent arbitrator.

Question 21: Do you agree or disagree with the analysis of this proposal set out in the accompanying impact assessment?

Question 22: Please provide any evidence you have to support your answer to question 21.

15% of respondents agreed with the analysis set out in the impact assessment. 46% of respondents were unsure. 39% of respondents disagreed. There were some concerns that the costs estimated in the impact assessment were too high, particularly around communications and the establishment of the scheme administrator, and that the evidence upon which these costs were based was limited and outdated.

Question 23: Are there are other means of delivering a cost effective and efficient household collection service to that described in question 18, with alternative delivery partners to local authorities and if so, what might that look like? 

A significant number of respondents answered that community drop off points should be trialled as an alternative to a household collection service, alongside numerous suggestions to trial more reverse logistics whereby delivery vans would do pick-ups on their regular routes.

Question 24:  Please provide any other comments and supporting evidence on the proposal for producers (and distributors that do not provide take-back services) to finance a system of kerbside collection of small WEEE and on-demand collections of large WEEE for households? 

Some concerns were raised around the potential cost of such a system and whether this could be justified, bearing in mind the evidence which suggests the collection rate would not be that high. Others commented that such a system may lead to some reusable equipment going to be collected as waste instead.

Question 25: Producers who place less than 5 tonnes of equipment on the UK market each year are exempt from financial obligations under the WEEE regulations. Does that 5 tonne threshold remain appropriate?

Question 26: If you answered no to question 25, what tonnage threshold is appropriate? Please provide evidence in support of an alternative threshold.

66% of respondents disagreed that this threshold was appropriate and a further 19% were unsure. Only 15% of respondents agreed that this tonnage threshold remains appropriate.

Respondents did not offer an alternative tonnage threshold.

Question 27: Are there alternative, non-regulatory approaches that could be established to increase separate collection of WEEE from households for re-use and recycling? If so, please describe what this might look like. 

Some respondents suggested some alternative regulatory approaches such as introducing a deposit return scheme for small electricals. Other non-regulatory approaches included increasing producer led communications campaigns to make consumers more aware of their disposal options for WEEE.

Chapter 2: Increasing distributor collections infrastructure

This section of the consultation asked questions around ways of enhancing distributors’ obligations in respect of collecting more waste electricals from their customers.

Question 28: Do you agree or disagree that internet sellers and retailers should provide a free of charge ’collection on delivery service’, requiring the free takeback of large domestic appliances such as washing machines, dishwashers, fridges, freezers and TVs?

76% of respondents agreed that internet sellers and retailers should provide a free of charge collection on delivery service, noting that this would lead to higher levels of collection for large appliances. There was an acknowledgement that items returned to retailers are more likely to be suitable for reuse.

17% of respondents disagreed that this service should be free of charge and that retailers should be able to charge a capped fee for the service so that the cost is visible to the consumer and not embedded in the price of the product.

7% of respondents were unsure.

Question 29: If you answered agree to question 28, should there be a reasonable time frame stipulated in which the unwanted item should be collected to allow for circumstances where it is not available for collection at time of delivery?

64% of respondents were unsure. 22% of respondents agreed that there should a be reasonable time frame stipulated and 14% of respondents disagreed.

Question 30:  What might a reasonable time frame be? 

49% of respondents answered that it should be 10 days.18% of respondents answered that 2 days would be a reasonable time frame. 26% of respondents answered that it should be 5 days. A further 17% of respondents answered that there should be no reasonable time frame stipulated.

Question 31: Should this service be extended to collection of smaller items when a large item is collected?

66% of respondents agreed that this service should be extended to collection of smaller items. 18% of respondents did not agree with this, while a further 16% were unsure.

Question 32:  Should retailers selling new household appliances as part of a new kitchen also be obligated to take away the old appliances from the household free of charge?

Question 33: Please provide any evidence you have to support your answer to question 32.

83% of respondents agreed that kitchen retailers should also be obligated to take away the old appliances free of charge and that they should be subject to the same obligations as other retailers. Respondents did not offer any substantive evidence in support of their response.

8.5% of respondents disagreed with this and a further 8.5% were unsure.

Question 34: Do you agree or disagree that we should extend the existing take-back requirements for large retailers from 1:1 to a 0:1 basis, for example by removing the requirement to purchase an item for the take-back obligation to apply?

60% of respondents agreed with this to make it easier for customers to dispose of their unwanted electricals. 24% disagreed, including many of the retailers who responded. A further 16% were unsure.

Question 35: Do you agree or disagree an obligation for retailers to take back WEEE on a 0:1 basis should be subject to reasonable limits as to the quantities of WEEE returned per householder?

75% of respondents agreed that such an obligation should be subject to reasonable limits. 14% were unsure and a further 11% of respondents disagreed.

Question 36: Do you agree or disagree that the definition of ‘large retailer’ should be any business with an annual turnover of electrical and electronic equipment of over £100k?

Question 37: Please provide any evidence you have to support your answer to question 36.

59% of respondents agreed with this definition, noting that this is the definition that has been used since 2019.

25% of respondents were unsure and 16% of respondents disagreed with this definition.

Question 38: if you answered disagree to question 38, what might an alternative threshold be?

This question was not widely answered. 2 respondents suggested that the annual turnover threshold should be set at a higher number (£0.5 million and £1 million respectively). One respondent suggested it should be based on number of appliances sold.

Question 39: Do you agree or disagree that the obligation should be restricted to retailers only taking back items that are similar to those sold in their stores?

Question 40: Please provide any evidence you have to support your answer to question 39.

75% of respondents agreed with this, arguing that it would be unfair for shops to take back items which they don’t sell in store.

13% of respondents disagreed, with some suggesting they should be required to take any item of WEEE back.

A further 12% of respondents said they were unsure.

Question 41:  Do you agree or disagree that an alternative obligation to 0:1 takeback should be available to internet sellers such as payment into a scheme, similar to the current distributor take-back scheme, to support increased levels of collections for re-use and recycling?

Question 42: Please provide any evidence you have to support your answer to question 41.

59% of respondents agreed with this, noting that due to the logistical constraints that internet sellers might face in offering a 0:1 takeback, it might be more efficient for them to pay into a scheme instead. Respondents felt that such a scheme must offer a robust, effective alternative and not a cheap alternative route of compliance.

27% were unsure and a further 14% of respondents disagreed.

Question 43:  Do you agree or disagree that the current information requirements should be enhanced to ensure customers are provided with information about their recycling options at the point of sale?

89% of respondents agreed, noting that the existing information requirement is not strong enough and that visibly communicating to consumers what their recycling options are is integral to driving up levels of recycling.

Only 5.5% of respondents disagreed and a further 5.5% were unsure.

Question 45: Do you agree or disagree that the point of producer responsibility should be moved to the retailer or internet seller’s premises (such as the retailer’s store, bulking point, distribution point)?

Question 46: Please provide any evidence you have to support your answer to question 45.

47% of respondents agreed with this, although expressed a view that such a service should be subject to minimum quantities to counter the carbon impacts of more frequent collections. A further 28% of respondents were unsure.

25% of respondents, mainly producers, disagreed, arguing that many retailers already organise WEEE collections, often via their chosen WEEE scheme, and so the duty to collect from their sites should therefore be with their WEEE scheme, and not a duty that falls on all producers.

Question 47: Are there any other obligations we should place on retailers and internet sellers to increase levels of collections?  

Question 48: Please provide any evidence you have to support your answer to question 47.

Many of the responses focused on ways of increasing consumer awareness of their recycling options, including clear product labelling and increased in store communications. Other suggestions included mandatory WEEE collection targets to be placed on retailers and internet sellers.

Question 49: Do you agree or disagree that online marketplaces and fulfilment houses should have ‘take-back’ obligations where they facilitate the supply of the product to the householder?

Question 50: Please provide any evidence you have to support your answer to question 49.

81% of respondents agreed, arguing that WEEE obligations and costs should be the same across different actors, regardless of whether or not the seller uses online distribution channels.

12% were unsure, noting that there is more work needed in order to establish how this would work in practice – without adding significant costs to the collection and treatment of WEEE for producers.

7% of respondents disagreed.

Question 51: How long will industry need to adapt to the proposals set out above?

Please select one of the following options:

Up to 12 months
12 to 18 months
18 to 24 months
24 to 48 months

Table 2: Breakdown of respondents’ preferred options

Response	Number of responses
Up to 12 months	87 (33%)
12 to 18 months	42 (16%)
18 to 24 months	49 (19%)
24 to 48 months	84 (32%)

Question 52: Please provide any evidence you have to support your answer to question 51.

No evidence was given to support these responses.

Chapter 3: Obligating online marketplaces and fulfilment houses

This section of the consultation asked questions around designating online marketplaces as a new category of producer, so that they contribute to the costs of separate collection and proper treatment of WEEE according to the market share of their overseas sellers in each category of equipment within the regulations.

Question 53: Do you agree or disagree that online marketplaces should be required to fulfil the producer obligations on behalf of their overseas sellers?

Question 54: Please provide any evidence you have to support your answer to question 53.

87% of respondents agreed, noting that large volumes of electricals are being placed on the market via online marketplaces and that we need to create a level playing field between producers who sell electricals via different distribution channels.

7% were unsure and 6% of respondents disagreed.

Question 55: Do you agree or disagree that fulfilment houses should be required to meet the producer obligations on behalf of their overseas sellers?

Question 56: Please provide any evidence you have to support your answer to question 55.

84.5% of respondents agreed with this, arguing that fulfilment houses provide a similar function to online marketplaces and therefore should be subject to the same obligations. 9.5% were unsure and only 6% of respondents disagreed.

Question 57: Do you agree that online marketplaces and fulfilment houses should initially be able to use estimated weight data using a protocol agreed with the environmental regulators?

Question 58: If you answered agree to question 57, please provide evidence to explain why exact data cannot be provided.

37% of respondents disagreed, saying that online marketplaces and fulfilment houses, like other types of producer, should have to use exact data. It was also felt that they should already have easy access to exact data.

35% of respondents were unsure.

29% of respondents agreed, saying that estimated weight data should be allowed for at least a limited period of time, as it may be more difficult for online marketplaces and fulfilment houses to access this data.

Question 59: What additional costs will accrue to online marketplaces and fulfilment houses as a result of becoming defined as a producer?  

Question 60: Please provide any evidence you have to support your answer to question 59.

Most respondents pointed out that additional costs would be similar to those of new producers placing electrical and electronic equipment (EEE) on the market. It was commented that they would not have to comply with parts of the regulations such as ensuring EEE is marked with the crossed-out wheeled bin symbol.  

Question 61: What other ways, if any, should the government explore to tackle the issue of non-compliance with the WEEE regulations by online sellers? 

Question 62: Please provide any evidence you have to support your answer to question 61.

Respondents suggested that more enforcement action is needed to tackle non-compliance amongst online sellers, including greater use of civil sanctions.

Chapter 4: Creating a new category of electrical equipment for vapes

This part of the consultation asked questions around creating a new category of electrical equipment for vapes. This would ensure that the costs of collecting and treating vapes would fall fairly on those who produce them.

Question 63: Do you agree with the proposal to create a new category for vapes? 

91% of respondents agreed with the proposal to create a new category for vapes, noting that at present the costs of recycling vapes are much more costly than other types of equipment and is not always being borne by those who produce them.

6% were unsure and only 3% of respondents disagreed.

Question 64: What additional costs will accrue to producers, compliance schemes and regulators as a result of creating a new category for vapes?

It was suggested there would be increased costs for vapes producers in terms of producer compliance scheme costs, data collection, market share obligations, engagement with producer compliance schemes, marking and labelling.

Conversely, it was also noted that there could be a decrease in costs for producers of other category 7 products, because the current regulations place vapes in that category which could result in them contributing to the cost of vapes collection and treatment.

Question 65: Are there any other measures, beyond those for eco-modulation and littering set out in the call for evidence, you think government should take to curb the environmental impact of vapes?

Many respondents favoured a ban on single use vapes. It was also noted that there needs to be more consumer awareness around how to properly dispose of their waste vapes, as well as greater enforcement action to deter users from littering.

Chapter 5: Scheme governance

This section of the consultation asked questions around the establishment of a new scheme administrator.

Question 66: Do you agree or disagree with the principle of establishing a government approved, producer-led scheme administrator to carry out specified functions in the reformed WEEE system?

Question 67: Please provide evidence to support your answer to question 66.

51% of respondents agreed. The majority of those that agreed recognised value in the economies of scale and efficiencies in some producer responsibility elements being undertaken centrally, coordinated or determined.

It was also largely agreed that the scheme administrator should be producer-led although there was also recognition that other stakeholders would also need to be involved.

35% of respondents were unsure, citing a lack of clarity over the definition of producer-led and raised concerns around the impartiality and transparency of such a scheme.

14% of respondents disagreed, noting that the scheme administrator may result in extra bureaucracy and therefore extra cost to the system.

Across the respondents, there was a theme that any such body needs to be held accountable by the government, who should set clear approvals criteria.

Question 68: If you disagreed with question 66, please set out details of an alternative approach to a scheme administrator.

Many respondents didn’t offer an alternative to a scheme administrator but instead considered that the scheme should be accountable to government, with a clear set of performance indicators against which it should be evaluated. A minority of respondents suggested that the scheme administrator should be a public body, acting in the public interest and through local council infrastructure, with some producer involvement.

Question 69: Which of the following functions do you think the scheme administrator should carry out? 

Options:

managing the producer balancing system for household WEEE (and non-household if necessary) 
administration of a distributor takeback scheme (for use by those distributors who are not required under the new system to offer in store take-back) 
development and administration of a compliance fee methodology in consultation with all producer compliance schemes, for approval by government 
providing evidence and forecasts of the likely household WEEE arisings – presenting recommendations to government to inform setting annual financial obligations placed on producer compliance schemes for household WEEE collections 
eco-modulation – support the government on potential new measures which could be applied to specific product categories, including development of a methodology upon which to base the modulation  
assess and report on environmental performance of the future system against key performance indicators with recommendations to government on measures to improve that performance

Over 90% of respondents were in favour of the scheme administrator taking on all these functions. Support for assessing performance against key performance indicators (KPIs), managing the producer balancing system and forecasting WEEE arisings were 98% or higher.

Question 70: Are there any additional functions the scheme administrator should carry out, in addition to those set out in question 69.   

Some additional functions suggested by respondents were:

acting as a central resource for collating evidence of large-scale non-compliance from registered producers, and reporting with evidence to regulators
monitoring cost effectiveness of the system
collecting, aggregating and making data on collection, reuse and recycling from the scheme publicly available and more user-friendly
holding WEEE operators and producer compliance schemes to account in terms of WEEE regulations interpretation and provide readily accessible interpretation for the public

Question 71:  Please provide any other comments on the role of a scheme administrator. 

There was emphasis around the body being evaluated regularly against a set of clearly defined KPIs. Most respondents agreed it should be industry led and comprise representation across the entire supply chain. It was also suggested that it should be referred to as the ‘WEEE system administrator’ to avoid confusion with producer compliance schemes.

Question 72: Which of the alternative performance indicators do you agree or disagree should be included in the future system? 

Table 3: Responses to question 72

Performance indicator	Number of respondents that agreed it should be included
Quantity or weight of WEEE in residual waste	221 (87%)
Convenience of recycling	198 (78)
Volume of WEEE in fly-tipped waste in each of the nations	161 (63%)
Level of consumer awareness of value and opportunities for reusing or recycling WEEE	182 (72%)
Regular assessment of the carbon impact the UK WEEE system	194 (76%)
Assessment of circular economy performance of the system	195 (77%)
Improvements in the quality of WEEE treatment processes	196 (77%)
Amount of WEEE diverted for reuse	232 (91%)

Question 73: Are there any other measures of success which government should consider to assess the performance of the system? 

Almost all respondents considered that there were no additional measures to those already captured.

Question 4

Annex 1: More detailed summary of responses

Accepted Answer

Chapter 1: Increasing household collections

This section of the consultation asked questions around the establishment of a producer funded household collection system for small and large items of WEEE.

Question 6: Do you agree or disagree that producers (and distributors that do not provide their own take-back services for electric and electronic goods) should finance collections of small WEEE (for example, toasters, small toys and tools), from households?

Table 4: Breakdown of responses to question 6

Response	Percentage of respondents
Agree	64%
Disagree	9%
Unsure	27%

Only 20% of producers agreed with this proposal and 71% were unsure. It was noted that the costs of setting up a household collection system may outweigh the benefits and that trials should be set up to test its feasibility. Likewise, 38% of distributors were also unsure and echoed the recommendation for trials.

In contrast, 88% of local authority responses agreed with the proposal, with many noting that householders need more convenient disposal options for their WEEE.

Waste management companies and approved authorised treatment facilities were also more likely to support this proposal, with 92% and 67% respectively agreeing that this proposal would drive higher volumes of properly collected WEEE, along with other benefits such as reducing risk of fires.

Question 8: Recognising the need to balance frequency of service with efficiency, what frequency should a WEEE collection round be provided?

Table 5: Breakdown of responses to question 8

Response	Percentage of respondents
Weekly	8%
Fortnightly	21%
Monthly	47%
On demand	25%

93.5% of producers said a monthly collection service would be best, noting that WEEE is not disposed of as frequently as other waste streams.

45.2% of individuals said they would prefer a monthly service, compared to 33.3% who favoured an on demand service.

Question 14: Do you agree or disagree that producers (and distributors that do not provide their own take-back services) should finance collection of large WEEE?

Table 6: Breakdown of responses to question 14

Response	Percentage of respondents
Agree	68%
Disagree	19%
Unsure	13%

83% of approved authorised treatment facilities (AATFs), 87% of local authorities and 86% of individuals agreed with this proposal, noting that this would reduce risk of fly-tipping and ensuring large WEEE enters the correct disposal channels.

Only 20% of producers and 39% of distributors agreed that this service should be free of charge and argued that local authority bulky collections and retailer collection on delivery for large appliances should be offered as a chargeable service, subject to a capped fee.

Question 16: Do you agree or disagree that a producer-led scheme administrator, approved by government, is best placed to determine the most practical and efficient delivery mechanism to manage producer obligations to finance small and large WEEE collections from households?

Table 7: Breakdown of responses to question 16

Response	Percentage of respondents
Agree	44%
Disagree	17%
Unsure	39%

77.8% of producers agreed that this should be producer led to ensure they can manage and control the costs of meeting their statutory obligations.

There was a wider mix of views amongst local authorities with 38.2% agreeing and 50% being unsure. It was noted that the scheme administrator would need to be accountable to government and consider the interests of not just producers.

Question 18: Do you agree or disagree that the most efficient and cost-effective delivery of the obligation to provide a regular household collection service for small WEEE and bulky waste collections for large WEEE is likely to be achieved through partnerships between a scheme administrator and local authorities and their waste management partners?

Table 8: Breakdown of responses to question 18

Response	Percentage of respondents
Agree	48%
Disagree	12%
Unsure	40%

67.9% of producers were unsure and favoured trials, which they would commission, to test whether local authorities had the capacity to manage the service effectively. It was also felt that producers should not be constrained to using local authorities and be able to explore other delivery partners.

59.2% of local authorities agreed, but many said that detailed arrangements should be determined locally and further work is needed to establish how those arrangements should fit with waste management companies, treatment facilities and re-use organisations.

Question 20: If you answered agree to question 16, what, if any, safeguards might be necessary to ensure costs incurred by producers in meeting the WEEE household collection obligation are reflective of the actual costs of delivery through their service partners? 

In addition to the scheme administrator establishing a test of efficient and effective service relative to profile of each local authority, and disputes being settled by an independent arbitrator, respondents also suggested the following safeguards:

for WEEE to be handed to producer compliance schemes free of charge
implementation of service over a minimum 4 year period.
in remote areas a bring service (bring banks) may be more appropriate
definition of small WEEE to be agreed locally
trials could establish whether local authority cost banding feasible (rural or urban)

Question 24:  Please provide any other comments and supporting evidence on the proposal for producers (and distributors that do not provide take-back services) to finance a system of kerbside collection of small WEEE and on-demand collections of large WEEE for households? 

No common themes emerged from this question. Some groups did highlight concerns around the costs as well as a lack of evidence on the marginal benefits of the scheme. The potential to divert products from reuse routes was also raised.

Question 25: Producers who place less than 5 tonnes of equipment on the UK market each year are exempt from financial obligations under the WEEE Regulations. Does that 5 tonne threshold remain appropriate?

Table 9: Breakdown of responses to question 25

Response	Number of responses
Yes	45 (15%)
No	193 (66%)
Unsure	54 (19%)

66% of respondents disagreed that this threshold was appropriate and a further 19% were unsure. 80% of producers felt the threshold was inappropriate to apply evenly across all categories and noted that 5 tonnes of vapes, or lamps, is very different to 5 tonnes of fridges, for example, both in terms of volumes and costs to handle and treat.

Only 15% of respondents agreed that this tonnage threshold remains appropriate.

Chapter 2: Increasing distributor collections infrastructure

This section of the consultation asked questions around ways of enhancing obligations placed on retailers and internet sellers to increase levels of convenience for householders seeking to dispose of waste electricals.

Question 28: Do you agree or disagree that internet sellers and retailers should provide a free of charge ’collection on delivery service’, requiring the free takeback of large domestic appliances such as washing machines, dishwashers, fridges, freezers and TVs?

76% of respondents agreed that internet sellers and retailers should provide a free of charge collection on delivery service. 58% of producers agreed and said it would lead to higher levels of collection for large appliances. There was an acknowledgement that items returned to retailers are more likely to be suitable for reuse. Some producers did think it should remain a chargeable service, however, but with a capped fee.

48% of distributors disagreed with this proposal arguing that removing the ability to charge would lead to them having to increase their prices, as an ‘invisible tax’ to all customers rather than only those actually using the service. It was also suggested that this proposal is not necessary alongside the proposal for producers to fund bulky waste collection from households.

Question 29: If you answered agree to question 28, should there be a reasonable time frame stipulated in which the unwanted item should be collected to allow for circumstances where it is not available for collection at time of delivery?

22% of respondents agreed that there should a be reasonable time frame stipulated.

83% of AATFs agreed with stipulating a reasonable time frame, along with 68% of producers. Only a third of distributors agreed with this.

The majority of respondents were unsure, including 89% of local authorities and 91% of waste management companies.

Question 30:  What might a reasonable time frame be? 

18% of respondents answered that 2 days would be a reasonable time frame. 26% of respondents answered that it should be 5 days. 49% of respondents answered that it should be 10 days. A further 17% of respondents answered that there should be no reasonable time frame stipulated.

Question 31: Should this service be extended to collection of smaller items when a large item is collected?

66% of respondents agreed that this service should be extended to collection of smaller items. This included 71% of producers and 74% of local authorities. 18% of respondents did not agree with this, while a further 16% were unsure.

There was an even split amongst retailers of 41% who agreed the service should be extended to include small items and 41% who did not.

Question 34: Do you agree or disagree that we should extend the existing take-back requirements for large retailers from 1:1 to a 0:1 basis, for example  by removing the requirement to purchase an item for the take-back obligation to apply?

60% of respondents agreed with this to make it easier for customers to dispose of their unwanted electricals. This included all producer compliance schemes responses, 70% of producers and 74% of local authorities.

24% disagreed that the obligation should be extended to a 0:1 basis, including 53% of retailers, some of whom said this new obligation would place new costs on their business, as well as pose issues regarding storage.

A further 16% were unsure.

Question 36: Do you agree or disagree that the definition of ‘large retailer’ should be any business with an annual turnover of electrical and electronic equipment of over £100k?

59% of respondents agreed with this definition, including 74% of producers and 87.5% of producer compliance schemes, who felt that this definition is appropriate as it has been used since 2019. Distributors had mixed views, with only 29% agreeing with the current definition, 33% disagreeing and a further 38% being unsure. Some distributors said that the threshold should also take into account other factors such as store size.

Question 38: if you answered disagree to question 38, what might an alternative threshold be?

Only a small percentage of those who responded to the consultation answered this question. 2 respondents suggested that the annual turnover threshold should be set at a higher number (£0.5 million and £1 million respectively). 1 respondent suggested it should be based on number of appliances sold.

Question 39: Do you agree or disagree that the obligation be restricted to retailers only taking back items that are similar to those sold in their stores?

75% of respondents agreed with this, arguing that it would be unfair for shops to take back items which they don’t sell in store. This included 88% of producers and 100% of producer compliance schemes. 83.3% of waste management companies also agreed, with some considering that it is important that the skills and systems that support the sale of specific items in retailers be used in the safe management of those items of a similar design when returned.

92% of retailers agreed, although with some suggesting that more clarity needs to be given as to what constitutes a ‘similar’ product.

13% of respondents disagreed, with some suggesting they should be required to take any item of WEEE back.

A further 12% of respondents said they were unsure.

Question 41:  Do you agree or disagree that an alternative obligation to 0:1 takeback be available to internet sellers such as payment into a scheme, similar to the current distributor take-back scheme, be used to support increased levels of collections for re-use and recycling?

59% of respondents agreed with this, noting that due to the logistical constraints that internet sellers might face in offering a 0:1 takeback that it might be more efficient for them to pay into a scheme instead. This included 86% of producers, 78% of producer compliance schemes and 54% of local authorities. Respondents felt that such a scheme must offer a robust alternative and not a cheap alternative route of compliance.

58% of waste management companies also agreed, largely saying that internet sellers are not best placed to collect at the point of delivery due to high reliance on couriers and that dedicated collections would be highly expensive.  Small mixed WEEE (SMW) should be collected through local authority routes, partly funded by internet sellers.

48% of distributors agreed, noting the need for a level playing field.

14% of respondents disagreed and a further 27% were unsure.

Question 43:  Do you agree or disagree that the current information requirements should be enhanced to ensure customers are provided with information about their recycling options ‘at the point of sale’?

89% of respondents agreed, noting that the existing information requirement is not strong enough and that visibly communicating to consumers what their recycling options are is integral to driving up levels of recycling. This included 93% of producers, 90% of producer compliance schemes and 98% of local authorities. 83% of AATFs also agreed and said that consumers need to be made more aware of their recycling options.

67% of distributors agreed. Some however felt that while public education on recycling is needed, retailers should not bear the sole responsibility of communicating this to the public.

Only 5.5% of respondents disagreed and a further 5.5% were unsure.

Question 45: Do you agree or disagree that the point of producer responsibility should be moved to the retailer or internet seller’s premises (such as the retailer’s store, bulking point, distribution point)?

47% of respondents agreed with this, although expressed concerns around this service being subject to minimum quantities to minimise the carbon impacts of more frequent collections.

25% of respondents disagreed, arguing that many retailers already organise WEEE collection, often via their chosen WEEE scheme, and so the duty to collect from their sites should therefore be with their WEEE scheme, and not a duty that falls on all producers. Only 7% of producers agreed with this proposal.

46% of distributors disagreed with the proposal, with some saying that if the government is to move the point of producer responsibility to retail and the doorstep, the extended producer responsibility concept would need to be fully embodied, meaning that producers will need to fully compensate all stakeholders operating collections. 

Question 47: Are there any other obligations we should place on retailers and internet sellers to increase levels of collections?  

Many of the responses focused on ways of increasing consumer awareness of their recycling options, including clear product labelling and increased in store communications. Other suggestions included mandatory WEEE collection targets to be placed on retailers and internet sellers.

Question 49: Do you agree or disagree that online marketplaces and fulfilment houses should have ‘take back’ obligations where they facilitate the supply of the product to the householder?

81% of respondents agreed, arguing that WEEE obligations and costs should be the same across different actors, regardless of whether or not the seller uses online distribution channels. This included 91% of producers, 89% of producer compliance schemes and 71% of distributors.

7% of respondents disagreed and a further 12% were unsure, noting that there is more work needed in order to establish how this would work in practice – without adding significant costs to the collection and treatment of WEEE for producers.

Chapter 3: Obligating online marketplaces and fulfilment houses

This section of the consultation asked questions around designating online marketplaces as a new category of producer, so that they are financially responsible for the EEE that is placed on the market via their platforms when it becomes waste.

Question 53: Do you agree or disagree that online marketplaces should be required to fulfil the producer obligations on behalf of their overseas sellers?

This proposal had almost unanimous support from across the industry.

100% of waste management companies, 92% of local authorities, 98% of producers and 90% of producer compliance schemes agreed with this noting that large volumes of electricals are being placed on the market via online marketplaces and that we need to create a level playing field between producers who sell electricals via different distribution channels.

83% of distributors also agreed with this proposal for the same reasons.

6% of respondents disagreed with this and a further 7% were unsure.

Question 55: Do you agree or disagree that fulfilment houses should be required to meet the producer obligations on behalf of their overseas sellers?

This proposal had widespread cross industry support with 84.5% of respondents agreeing. This included 93% of producers, 78% of producer compliance schemes and 85.5% of distributors.

Most argued that fulfilment houses provide a similar function to online marketplaces and therefore should be subject to the same obligations.

Only 6% of respondents disagreed with this and a further 9.5% were unsure. Those who disagreed did not provide any further comments.

Question 57: Do you agree that online marketplaces and fulfilment houses should initially be able to use estimated weight data using a protocol agreed with the environmental regulators?

29% of respondents agreed with this, saying that estimated weight data should be allowed for at least a limited period of time, as it may be more difficult for online marketplaces and fulfilment houses to access this data. This included 67% of waste management companies.

37% of respondents disagreed with this, saying that they, like other types of producer, should have to use exact data. Many of those who disagreed were producers (81%) who argued that they should be subject to the same data requirements as other types of producer. It was also felt that online marketplaces and fulfilment houses should already have easy access to exact data.

Question 59: What additional costs will accrue to online marketplaces and fulfilment houses as a result of becoming defined as a producer?  

Most respondents pointed out that additional costs would be similar to those of new producers placing EEE on the market. It was commented that they would not have to comply with parts of the regulations such as ensuring EEE is marked with the crossed-out wheel bin symbol.  

Question 61: What other ways, if any, should government explore to tackle the issue of non- compliance with the WEEE regulations by online sellers? 

Those who responded suggested that more enforcement action is needed to tackle non-compliance amongst online sellers, including greater use of civil sanctions.

Chapter 4: Creating a new category of electrical equipment for vapes

This part of the consultation asked questions around creating a new category of electrical equipment for vapes. This would ensure that the costs of collecting and treating vapes would fall on those who produce them.

Question 65: Are there any other measures, beyond those for eco-modulation and littering set out in the call for evidence, you think government should take to curb the environmental impact of vapes?

Many respondents, including producers, AATFs, waste management companies and local authorities favoured a ban on single use vapes. It was also noted that there needs to be more consumer awareness around how to properly dispose of their waste vapes, as well as greater enforcement action to deter users from littering.