Recommendation 2

HM Government · verbatim extract Rejected

We note the Committee’s concern around the use of substantiated estimates and potential issues with their reliability. We know that a significant amount of white goods such as cookers and washing machines, are treated and properly recycled outside of the producer funded WEEE system. They have an intrinsic scrap metal value that results in a payment made by metal recyclers to collectors on delivery of these items for treatment. For this reason, significant quantities are managed outside the system of collection and treatment, financed by producers that is established by the 2013 WEEE Regulations. Nevertheless, it is important to understand the volumes of equipment that is captured outside of the producer led system to assist in setting meaningful targets and to gather evidence on the wider environmental impacts of policy. The use of estimates based on research minimises burdens on businesses, often SMEs that would otherwise have to report data. It is also worth noting that the current legislative framework specifically provides for the use of “substantiated estimates” in reporting requirements and that such reporting should cover WEEE collected from all routes – not just that financed by producers. The data and methodology is based on a study undertaken by WRAP and we have high confidence in this methodology. We intend therefore to continue using these estimates where it is helpful to do so in understanding more about the flow of WEEE outside of that which is financed by producers