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The European Point-of-use Drinking Water Association is seeking government clarification on the Waste Electrical and Electronic Equipment (WEEE) directive, following predicted costs of up to £30 per water cooler. In this issue, the EPDWA's President James Anderton explains its case. The WEEE legislation (Waste of Electronic and Electrical Equipment) will come into full effect on 1 July 2007 and for the water cooler industry, like many others, the situation is becoming serious. The EPDWA has added its voice to the Department of Trade and Industry (DTI) consultative process, which ended on 17 October, to ensure that the interests of the water cooler industry are defended. Depending on the way the WEEE legislation is implemented, it is estimated that it will cost the industry between £20 and £30 per cooler for recycling - for an estimated 100,000 coolers per year, this will mean a total cost to the industry of up to £3 million per year. These are substantial sums which no one in the industry can be expected to absorb, and inevitably the end user will have to pay. Most distributors are already building up a “war chest” by charging an environmental surcharge on their invoices. If you represent one of the few companies which is not doing so, the EPDWA would urge you to consider it very seriously - experience suggests that the great majority of end users readily accept the need for recycling and any related cost. What are these costs? The cost of WEEE can be split into three distinct elements: 1. freight 2. recycling 3. administration of the process Based on the following assumption, it is possible to calculate the total cost of WEEE for goods shipped directly from the distributor to the recycler. • 75 miles distance from the recycler to the distributor or “producer”. • 100,000 units to be recycled per year. • WEEE collection and disposal by Environmental Services: £11.50 per unit per pallet of 12, plus a Hazardous Goods charge of £25.00 per shipment - £13.60 per cooler. • Administration cost: based on the assumption that two additional heads at £40K would be required for every 5,000 units, the cost per cooler is £8.00. The cost per cooler therefore comes to £21.60. The cost to the industry for 100,000 coolers is £2.1 million - and the environmental cost of WEEE is 750,000 WEEE transport miles. If, for an unknown reason, WEEE needs to be returned by the distributor to the “producer” (the UK manufacturer or importer) who then has to pass the goods on to the recycler, the cost escalates significantly as follows: • WEEE collection and disposal doubles, because of double handling, to £27.20 per cooler. • The administration costs again double to £16.00 per cooler. The total cost per cooler therefore comes to £33.20. The total cost to the industry for 100,000 coolers comes to £3.32 million - and the environmental cost of WEEE doubles to 1.5 million WEEE transport miles. WEEE is currently considered Hazardous Goods. This means that it has to be accompanied by a Hazardous Goods Notice with the name of the driver and the vehicle registration number. This means new coolers can be shipped by normal transport, but WEEE can no longer be shipped normally. This is a strange anomaly, especially in view of the fact that all coolers must be RoHS (Restriction of Hazardous Goods) compliant. Few of this industry’s transport companies would be able to cope with this – but of course everything is possible at a price! WEEE represents a massive challenge to the industry, not only in cost but also in administration. Every cooler needs to be traceable and registered with the authorities, although it is not clear yet with whom. There is a suggestion to have a “bond” set up when the cooler is first placed, to cover the cost of future recycling. This will involve more administration. Then imagine you will need to take away and recycle around 20% of your coolers per annum – assuming an average cooler life span of five years. The EPDWA has arranged to meet with the British Water Cooler Association to agree on a common industry position to be put forward to the DTI. We are, of course, not the only industry to lobby the DTI – but we will do our best to represent you.