A case of wait and C?

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The Government recently outlined its proposals in the final consultation document for how the Batteries Directive will operate in the UK. Its proposals have left those that are obligated by the new legislation confused and concerned. Producers are claiming that the Government’s proposals need much further thought and modification before the directive is introduced if the UK is to hit the stringent collection and recycling targets expected of it.

It may be an old adage, but it’s very true: you wouldn’t build a house without putting the foundations in place first. And, like a house, you need strong cornerstones to make sure the whole thing doesn’t fall down. The Batteries Directive is no different and, just months ahead of its implementation, it’s still missing the cornerstones – the four C’s needed to make the legislation a success in the UK.

Compliance

As yet, even the most basic detail of the directive – the compliance scheme structure – is still to be decided upon. In its final consultation document on the directive, the Government has laid out its support for a multiple, competing compliance network, much like the system used for compliance in the WEEE Directive.

The Government believes this will mean better service, value for money and more choice for producers. But this approach goes against the wishes of many in the industry who believe that either one national compliance scheme or a small number of multiple compliance schemes with a co-ordinating body is the way forward. If one looks at the competing nature of the WEEE compliance schemes – at present there are 42 different schemes registered and, throughout the lifetime of the directive being in force – there have been serious misgivings about the accuracy of reporting. 

With ambitious, but achievable targets to hit, accuracy of data will be key. Having one or a very limited number of compliance schemes with one controlling body, means consistency of reporting across the industry, rather than having results spread across numerous organisations. The competing nature proposed also means a dilution of effort at a time when the industry needs to be working together to tackle the challenge.

Finally, the competing compliance scheme model will also create a number of knock-on effects into other areas of the directive such as publicity campaigns and collection schemes, again possibly hampering or confusing the recycling and collection effort across the UK.

Cost 

When any new legislation is introduced, the cost of implementation and obligation are often bones of contention and the Batteries Directive is no exception. For a compliance scheme to make an application it will cost £17,000 and once it is approved, it will have to pay £149,000. To many in the industry, this is steep and has left much confusion as to what they will get in return. The additional £5,000 fee for monitoring large members also seems high and unnecessary.

This is also the mindset of the industry towards the amount the Government is earmarking to monitor the directive. The Government has outlined its hopes to generate an annual income in excess of £650,000 to fund the Environment Agency to enforce the legislation. But isn’t this a little excessive, especially if the experiences of the WEEE Directive are taken into consideration, such as poor publicity, continued confusion amongst businesses and a lack of communication with the end-user?

Transparency and value for money is the key here. Producers and other obligated companies will not mind spending the money if they feel the service they will receive will make a difference. This figure could actually be significantly higher, due to the small producer exemptions currently proposed by the Government. As it stands, small producers which place less than three tonnes of portable batteries per year on the market must register with a compliance scheme but will not be obligated to finance the collections.

However, if we look more closely at the figures, then this surely needs to be re-thought. The current threshold is set too low and could mean that out of 1,000 obligated producers, only 50 to 100 could be liable to pay any compliance scheme costs, creating significant additional financial burdens to offset the non-obligated producers. This exemption could lead to ‘tactical restructuring’ by mid-sized producers ‘splitting up’ their companies into smaller divisions to qualify as small producers.

Collection

The actual collection of the batteries is another area that is still a growing concern. From a consumer point of view, any method implemented needs to make recycling as easy as possible. It is evident that many householders are confused and turned-off by household recycling schemes, as they require extra effort and people are forced to handle and live with their waste for longer periods of time.

Many also fear that, due to the competing compliance scheme structure proposed, schemes will focus on the areas that offer the most profit, such as large urban areas, while remote and sparsely populated areas will be neglected.

A better solution would be to follow the lead of other European countries and utilise the high footfall locations that consumers visit on a daily basis such as retail outlets, post offices, petrol stations and even schools. This means little effort on the part of the consumer and more chance of success in terms of hitting collection targets.

This approach is something that could work well in the UK and assist with the marketing around the directive, reaching consumers directly as they go about their daily lives, especially in supermarkets and post offices.

Communication

All other issues covered would be meaningless if the Directive’s aims are not communicated properly. Despite the breakdown of communication around the WEEE Directive, it seems that the Government has not learnt from its mistakes, as it will not be funding an ongoing national campaign to educate the end-user about the Batteries Directive.

The decision to leave the majority of the education to the producers and compliance schemes has left the industry baffled. Without the Government leading communication, how is the consumer meant to know about the directive, the role they are to play, key upcoming dates and whether the nation is on track to achieve its targets?

The problem of communication is made all the more difficult due to the proposed competing compliance scheme structure. This will bring a dilution of the messages that reach the end-user as each compliance scheme will have its own smaller PR and marketing campaigns – ultimately competing against each other for air time and column inches. As a result, the messages will reach a smaller cross-section of people and not have the same impact as one universal campaign.

A Government-supported campaign would mean that a strong and consistent voice is heard by the target audience which could be distilled down for local interpretation based on the collection routes for that area. It’s imperative, therefore, that the Government listens to the wishes of the industry – the people who operate in the market on a daily basis. If not, those obligated by the directive have to work within a legislative template that they don’t believe in, damaging and dampening the current positive attitude that exists within the sector. The fundamentals need to be addressed before the UK can even consider hitting its targets.

The four C’s outlined here are the cornerstones of success, and if even one is neglected, there will be one further C to add to the list – catastrophe.

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