Good afternoon Ladies and Gentlemen,
It’s a pleasure to be with you in the ever-impressive environs of the RDS. I’m minded today to recall how the Royal Dublin Society developed from a small group of concerned individuals united by a common aim to improve the economic condition of the country by promoting agriculture, arts, industry and science in Ireland and has continued to grow over the years.
The society has never sat back and rested on its laurels, it has instead actively pursued opportunities to develop and grow. The campus here is an example of this, growing in size over the years from 15 to 40 acres.
It’s fair to say that there is much to be learnt from this venerable organisation in terms of member democracy, corporate social responsibility and community identity. The key to the success of organisations like the RDS lies in an ability to deliver today, while preparing for the challenges of tomorrow; always asking what’s next?
I would like to thank the Chairman of WEEE Ireland, Kieran Whelan, for inviting me here today and affording me the opportunity to share with you my views on what’s next for WEEE Ireland. Specifically, I want to use my time with you here today to illustrate how my Department is preparing for the challenges of WEEE 2 implementation in Ireland.
WEEE Ireland
While WEEE Ireland is in its infancy as an organisation compared to the RDS, I think that it’s fair to say that its name, through your own innovation and creativity, is now firmly embedded in the public’s psyche as a brand when they think of the disposal of their electrical waste.
This has been accomplished because WEEE Ireland has delivered; it has delivered for its producer members; it has delivered for the public and it has delivered for Ireland and our environment. The statistics are impressive and, while they have already been well rehearsed, they are worth repeating. Since being approved as a compliance scheme WEEE Ireland has:
contributed some 34.5 million euro towards WEEE recycling in Ireland;
collected over 200,000 tonnes of WEEE;
exceeded the first EU portable battery collection target as well as all WEEE collection, recovery and recycling targets.
This could not have been achieved by anything other than a truly committed executive team, leading a very talented and dynamic organisation. I’m glad to be able to say that the relationship between my own Department and WEEE Ireland is excellent and is characterised by a shared commitment to developing the most effective WEEE collection and recovery system we can for the Irish people and our environment.
For all your achievements, I would say congratulations and thank you. Being a politician though, I would then quickly tell you to get ready for what’s next!
WEEE 2
What’s next is the transposition of a new WEEE Directive and the introduction of higher collection and recovery targets. Key changes to the Directive include:
a wider scope for the range of products covered;
an increased emphasis on re-use which will challenge us all to co-operate in order to establish an effective, viable and progressive national WEEE re-use regulatory system in Ireland;
the introduction of the concept of a producer’s authorised representative in an effort to lower the regulatory and cost burdens on business;
new tools to fight the illegal export of WEEE more effectively;
the introduction for the first time of a one for zero take back requirement with respect to small items of WEEE in retail outlets of a certain size;
the introduction of higher Member State collection and recovery targets and a changed methodology for calculating the WEEE collection rate.
Much work has already been done in preparing Ireland to meet these new challenges.
Last year, I commenced a review of the Producer Responsibility System in Ireland with a view to ensuring that the structures we have in place are optimal to meet the environmental challenges we face in this sector.
The wide-ranging nature of the PRI review will provide me with an overall assessment of the existing regulatory structures and will assist my Department in formulating proposals to further improve our current regime.
Once again, I want to thank all of the industry stakeholders and the Board and management of WEEE Ireland who have provided their valuable input into the review.
I will be publishing the WEEE module of the report shortly and I would encourage you all to study its recommendations. The options presented will be carefully considered by my Department with a view to determining how they will positively impact on the implementation of WEEE 2 in Ireland. They will also be considered alongside the work which has already been completed by sub-groups of the National WEEE Monitoring Group which I charged with examining the most challenging aspects of the new Directive, namely targets, finance and re-use.
I would like to commend these groups for the quality of the reports they have produced and which have been considered by my Department in preparing the draft National WEEE 2 Regulations. I would also like to thank WEEE Ireland for their active participation in these sub-groups.
In that regard, I am pleased to take the opportunity of today’s conference to formally launch the public consultation on the implementation of the WEEE recast Directive in Ireland. The consultation document and associated draft regulations can be accessed on my Department’s website from four o’clock this evening and I look forward to considering your submissions in due course.
This will be an intensive three-week consultation process, which reflects the level of continuous engagement my Department has had with stakeholders since this Directive was being negotiated in Brussels. The time frame also reflects the necessity for stakeholders to quickly assess the draft Regulations and give their final views, opinions and possible solutions on how the national WEEE regime will work.
I am proposing a package of measures in this consultation that, I believe, draws on our considerable experiences to date and provides the regulatory framework that will build upon the success we have together achieved.
While this success is not due to any single factor, I would like to acknowledge the role the Irish public have played in embracing the WEEE system in Ireland and utilising fully the network of collection facilities and options available to them.
They have demonstrated their commitment to the Irish environment and have played a fulsome role in eradicating the visible blight on our countryside and towns caused by waste fridges and washing machines and other electro-scrap. It is clear that the public has supported us from day one. They saw the benefits and I’m confident they will support the type of initiatives that are required. The public will not be found wanting and we owe them a debt of gratitude that is best repaid by redoubling our efforts to facilitate further recycling, to allow us to fully become a recycling society.
It is of critical importance that this key stakeholder is never taken for granted but rather that they be encouraged and facilitated in every way possible to dispose of their WEEE through the appropriate channels. In this context, I am proposing to introduce more flexible return options for members of the public, improved access to civic amenity sites and an increase in the number of special collection events and kerbside collections organised by the schemes.
I appreciate that WEEE Ireland have expanded their collection network with WEEE to work days and door-to-door collections and collections in housing estates. This is a flexible collection option which offers maximum convenience for members of the public. The recast Directive recognises the importance of providing the most flexible collection options for the public in order to avoid WEEE becoming the object of sub-optimal treatment and illegal handling. It provides Member States with the option of requiring producers to finance the collection of WEEE directly from households and such a bold proposal deserves the most careful scrutiny.
The interface between the consumer and the electrical retailer has been a corner stone of the system to date. This is illustrated by the fact that, in 2012, 46.3% of WEEE Ireland’s collections were from retailers. To achieve future collection targets, retailers are going to play an even more important role in WEEE collection. Retailers face challenging conditions at present and I believe we need to reduce the administrative burden of environmental legislation on this sector, provided that there is no lessening in environmental performance or standards. I am also prepared to consider initiatives from producers which will support retailers in meeting their WEEE regulatory obligations, provided that there is demonstrable evidence that any such initiative will impact positively on reaching our targets.
However, what I am not prepared to countenance is any contravention of retailer take-back obligations or any action on their part which results in WEEE being diverted from authorised collection channels. The draft regulations provide for a greater role for the Environmental Protection Agency
in enforcement in this regard and are explicit in stating that all WEEE collected at retail outlets can only be transferred to self-complying producers or to the schemes as appropriate. This is a red line issue.
I want to see retailers viewing their WEEE management as a normal part of their day-to-day responsibilities, whereby their participation is clear and transparent to the public and is not viewed as some nefarious burden imposed upon them by Government, to be avoided or exploited as circumstances permit. I want to see retailers supported by producers in creating a culture of compliance which remains a corner stone of our national WEEE collection system; a system dependent on the vagaries and fluctuations of the metal markets is not a sustainable one.
It is my view that any financial contribution to retailers to cover the costs associated with handling WEEE should also be extended to Civic Amenity Facilities. Collections from CA sites for the period June 2012 to July 2013 was in the order of 15 thousand tonnes. This at a time when receipts from the landfill and plastic bag levies continue to fall with consequent reductions in the level of support the Department can provided to these facilities.
The continued decrease in the Environment Fund means it may not be possible for the State to continue to subvent the costs of WEEE collected at Civic Amenity Facilities and this may have a negative effect on the overall WEEE collection rate.
I will be examining the recommendations of the PRI WEEE report in this regard with a view to how schemes can make a meaningful contribution to ensuring that this vitally important collection network can continue to contribute to the attainment of Ireland’s WEEE targets.
Under the Directive, there is a new requirement for retailers with sales areas relating to electric and electronic equipment exceeding 400 square meters to take back very small WEEE. This is a welcome initiative that has the potential to divert significant volumes of such WEEE from wheelie bins. We need to recover more of these items and this new measure affords us the opportunity to do so. It will require innovation from compliance schemes to support retailers and will involve schemes investing more in expanding their current operations and promoting greater public information and awareness.
Indeed, now is an opportune time to re-evaluate the nature and scale of the information we are providing to the public. Efforts have been made previously in this area of course, but there is increasing evidence that core recycling messages have become diluted at the expense of brand promotion.
It’s time to get back to basics and push the core messages that:
WEEE recycling is free,
WEEE must never be deposited in waste disposal bins, and
there are many options and facilities available to members of the public to support them in managing their WEEE properly.
My Department will be discussing the requirement for better message co-ordination between the two schemes further and I look forward to receiving joint proposals on how to advance this in due course.
Visible Fees
It has been argued that the visible fee introduced as part of the initial WEEE regime contributed to enhanced consumer awareness of their obligations and rights when disposing of WEEE. The fact that the recast Directive permits Member States to show purchasers the costs of collection, treatment and disposal of EEE in an environmentally sound way at end-of-life is testament to this fact.
In preparing for the future, we must be cognisant of the past. While a system of visible fees across a range of Member States succeeded in generating the funds to start up and subsequently operate compliance schemes, it has to be recognised that the level that the original fees were set caused problems. While certain assumptions had to be made back then in the absence of comprehensive data, these fees enabled schemes throughout the EU to build up unacceptably high reserves. The good work of the WEEE Register Society in periodically reviewing the level of the fees here in Ireland was important in this regard.
The key questions on visible fees facing policymakers throughout Europe now in preparing for WEEE 2 include:
are visible fees contrary to the principles of enhanced producer responsibility and the internalisation of production costs?
are end-of-life costs just another cost associated with bringing the product to market which should be properly internalised in the retail price?
how exactly will the funds generated from visible fees be expended?
can visible fees make a significant contribution to the attainment of targets and how? And, crucially,
what levels should any such fee be set?
I have already spoken about my intention to reduce the administrative burden on the retail sector in terms of compliance with the new WEEE Regulations. I think it’s fair to say that retail representatives have traditionally viewed visible fees as an imposition because of the very substantial IT costs incurred and that their preference is that in the future recycling costs should be internalised into the final cost to the consumer, just like all other product costs.
Finally, in relation to the fundamental question of whether I intend to re-introduce visible fees in the forthcoming Regulations, I appreciate the support which exists for visible fees amongst certain stakeholders, including WEEE Ireland. I also have taken careful note of the report prepared by Jim Power who has spoken earlier today at this conference.
I understand that the Financing Sub-Group of the National WEEE Monitoring Group in the context of a number of recommendations regarding financing have recommended that their re-introduction be considered. However, I note, with some regret, that there is no consensus amongst stakeholders on the National WEEE Monitoring Group on how a regime of visible fees might operate. Given this scenario, the draft Regulations, which are issuing today, do not contain any provisions regarding visible fees. However, should industry move to a position where a consensus exists on this issue and how it would operate, I am prepared to consider any further proposals which might emerge during the period of the consultation.
Re-use
It is important in preparing the legislative framework that we transpose not only what is required to implement the Directive in Ireland but anticipate the direction the European Commission will ultimately take us. While there are no specific targets to be met in terms of re-use, it is right that we take the steps required today to establish an effective, viable and progressive WEEE re-use regulatory system in Ireland in order to meet the targets that the Commission will ultimately ask of us tomorrow. To quote Peter Drucker, “The best way to predict the future is to create it”.
There are perceived barriers to re-use, with improved energy efficiency of new appliances and the increasing obsolescence of new products in a throw-away society being obvious examples. We must, however, recognise that by extending the product life, re-use enhances resource efficiency and saves energy, thus reducing overall environmental impacts.
Repair and re-use of WEEE is already well developed in Ireland, particularly in the social economy sector. Not-for-profit organisations dealing with re-use, while contributing hugely to waste management ecological issues, also play an extremely valuable role in the provision of training and job opportunities for workers and provide an alternative source of goods for low-income households.
The key to re-use organisations developing further is access to product and the Directive requires Member States to provide access to WEEE suitable for re-use at collection points. The draft Regulations provide for such access in a co-ordinated, efficient and effective manner for approved re-use organisations. This approach will avoid further costs and builds on the existing arrangements and relationships with producers, while also facilitating the recording of WEEE being prepared for re-use. In addition I will be setting ambitious targets in the scheme’s conditions of approval to ensure that re-use is given due consideration.
I am grateful to the WEEE Register Society who will approve and register re-use organisations for the purpose of the Regulations and who, in conjunction with my Department, will establish the criteria and standards required in order to be recognised as an approved re-use organisation.
Conclusion
I believe that the draft regulations I’m publishing today demonstrate Ireland’s continued ambition and enthusiasm in our approach to formulating our WEEE policy. I believe these regulations recognise the important contribution producers of electrical and electronic equipment continue to make to the Irish economy but also re-affirm our commitment to the concept of producer responsibility and the Polluter Pays Principle which underpins much of our waste policy.
The regulations can provide us with the road-map to further reduce the adverse impact on the environment from the generation of this particular waste stream and charts a path towards an innovative, modern and sustainable approach to the management of WEEE.
Their implementation will represent
a significant challenge to us all, but, as Henry Kissinger once remarked - “The task of the leader is to get his people from where they are to where they have not been”. I look forward to working with WEEE Ireland and its members in taking Ireland onto a new plain of environmental performance in terms of WEEE collection, treatment and re-use in the years to come.
Thank you for your attention, I look forward to your contribution to the consultation process and I wish you all a productive day in your discussions.