Defra report on implementing eco-modulation into the UK's WEEE system

The first phase of this project was to explore, with supporting evidence, the mechanics and systems elements required to create an eco-modulation system in the UK that can facilitate and reward the eco-design of electrical and electronic equipment (EEE) in a cost-effective manner. Any UK system must work in accordance with the current Extended Producer Responsibility (EPR) legal framework and the UK’s existing waste management strategies on recycling and would seek to reward resource efficiency at the design phase by enabling the reduction of waste generated and reducing negative environmental externalities through, inter alia, the use of less environmentally harmful substances and the extension of products’ lifetime.

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Published on Feb 15, 2023

In the last two decades, the EU has sought to incentivise the eco-design of EEE through multiple policy packages, notably the WEEE Directive, the Eco-design Directive, and the Waste Framework Directive. All three Acts were introduced in the 2000s and have since been amended and recast to expand their scope and level of ambition. The Waste Framework Directive in its three iterations to date has restated the need for Extended Producer Responsibility (EPR) to support the eco-design of products to minimise the impact of waste management systems on the environment. These Directives form part of the EU laws retained since the UK’s departure from the European Union.

This study restricts the focus of analysis on the recycling costs as opposed to the lifecycle of products. The modulation of the end of life (EOL) compliance costs that producers pay into the producer compliance schemes, known as eco-modulation, has increasingly been proposed as an incentive mechanism to overcome the failure of EPR in encouraging producer ecodesign. Such eco-modulation systems see producers’ EPR fees and obligations adjusted based on the level of eco-design integrated within their products, while also leading to a differentiated distribution of costs among producers based on their alignment with modulation requirements.

To understand how this might work for the UK, this study includes:

Insights and best practices from other countries where eco-modulation has already been implemented – namely France, Italy, Taiwan and the Canadian province of Ontario. The evaluation of these existing eco-modulation systems includes the mechanisms and modulation criteria utilised.
Data modelling and analysis of confidential UK waste data to explore the scenarios and levels of waste that might be reduced through eco-modulation and subsequent financial savings
Insights from one-to-one interviews and a stakeholder workshop on practical implementation and qualitative viewpoints from industry including two France-based producers, three UK-based AATFs (approved authorised treatment facilities), two PROs (one based in France and the other in Canada) and a major UK trade association (techUK) which has over 850 members including large brand technology producers. The workshop was attended by a range of stakeholders including ten EEE producers, five European PROs, four UK compliance schemes and numerous WEEE recyclers.
Exploration of suitable eco-modulation criteria to incentivise change in EEE product design via analysis of more than 350 criteria used for EEE eco-modulation in four jurisdictions: South Korea, Taiwan, France, and Ontario, Canada.
Insights from three UK-based AATFs that recycle/ repair different product categories including small WEEE, large domestic appliances and fridge/freezers.
An assessment of the products and criteria used in the UK’s current eco-design legislation to see how they compared to that of eco-modulation. Several EEE product categories are both within the scope of the eco-design regulation and could be potentially affected by eco-modulation criteria.
Evaluation of potential metrics for eco-modulation such as weight and units placed on the market (POM) whilst also aligning with measurements used to measure EPR responsibility within the UK and other jurisdictions.
Exploration of the mechanism of implementation: (i) adoption of modulated POM fee, (ii) modulation of market share obligations and (iii) Deposit Return System (DRS) based on the mechanisms deployed globally and that fit within the potential of the UK's EPR framework.

Download the report now to read the 7 key findings identified including a summary of the success factors for the implementation of an eco-modulation system in the UK and key Recommendations.

The second phase of the project, and accompanying report, explores options aimed at reducing the environmental impact of Energy-related Products (ErP) across their lifecycle with particular focus on production and disposal. The research sets out a methodology for prioritising the most impactful ErP based upon carbon footprint and waste generation, and then presents an appraisal of policy options. Click here to download this report.