At your disposal

Few users of lamps and luminaires will argue against recycling and proper disposal of the products at the end of their useful life. It is good health and safety practice, as well as good for the environment. It is also part of the wider issue of corporate social responsibility.

In the past, proper disposal has been a duty of care for the end-user, not a legal obligation. That is about to change. On 1 July, the EU Waste Electrical and Electronic Equipment directive, or WEEE, kicks in. And when it does, the onus for disposal of electrical and electronic goods will be on their producers, whether manufacturers, importers or re-branders (see box on p44). “End-users will no longer have the hassle of disposal contracts,” says Peter Lees, commercial manager at recycling scheme Recolight.

Recolight is an initiative of the major UK lamp manufacturers who, in turn, are members of the European Lamp Companies Federation. It was set up four years ago by the four main UK lamp suppliers – Philips, Sylvania, Osram and General Electric – to handle their lamp recycling to meet the legal obligations of WEEE. The scheme liaises with customers, end-users, transport companies, recyclers, government and regulators.

A similar scheme, Lumicom, has also been established for the producers of non-household luminaires by the Lighting Industry Federation. This scheme deals with everything in a luminaire, except for the lamps themselves.

Both Recolight and Lumicom are now busy organising and paying for recycling processes. Recolight will finance the costs of collection from designated collection facilities (DCFs) located on the 1,100 UK council rubbish tips or refuse collection stations. It will also help establish further DCFs where needed. “Upwards of 3,000 DCFs will be under Recolight’s control by the end of 2007,” Lees estimates.

There is even a facility for lamp collection. End-users can contract that first mile to Recolight, who will set up an on-site collection facility for later transportation to a DCF or a recycler, if needed. However, Recolight will not automatically collect from an end-user’s doorstep in order to deliver the waste to a DCF, and the cost of the first leg of the disposal journey will remain the end-user’s responsibility.

Where collection facilities are set up on construction sites, these must meet environmental legislation requirements for the protection and confinement of toxic substances.

The site must also contain sufficient lamps to make regular pick-ups feasible. “Fifteen lamps a fortnight will not be worth Recolight’s collection effort,” explains Lees.

By law, the producer has to be accredited to a compliance scheme, such as Recolight or Lumicom, to prove it has undertaken its recycling obligations. As with any business, the cost of providing a service is passed up the supply chain, eventually reaching the end-user. Lees would like to see an environmental recycling charge “as a visible fee” on the producer’s invoice, which he estimates will probably be about 15 p to 25 p per lamp. The buyer, likely to be the wholesaler, then has proof the goods were bought in good faith.

Large-volume end-users will be able to offset this environmental charge against the saving of not having to set up disposal contracts. At the moment, small businesses using only a few lamps can take them to council sites and leave them as part of consumer waste for recycling at no cost to themselves.

Henrietta Lynch, sustainability consultant with Building Design Partnership, believes WEEE is good in principle, but she has concerns about the recycling process. A major concern for many end-users will be whether they have sourced their lamps and luminaires from accredited producers so that disposal is paid for. “We’ll probably see a clause in a lot of contracts where the end-user will want equipment to be sourced from accredited producers,” she says. “This could be a headache for many facilities managers if they are caught recycling non-accredited lamps.”

Lees says the scenario of non-accredited lamps being recycled is unlikely. “In reality, 85% of lamps used in the UK come from the big four,” he says. Recolight and authorised recyclers of lamps will be sampling batches from skips that arrive to be recycled. There will be a list of brands that are bona fide products to be recycled because their producers have signed compliance agreements.

Lees expects the Environment Agency and the contracted recycler will spare no effort to trace where illegal goods are coming from. Under current rules, fines can be up to £2,500 per conviction. “But I suspect isolated cases will get a warning letter and prosecutions would be only for repeated incidents involving large quantities of product where traceability to source is possible,” he says. Lees’ advice to end-users is simple: “Written proof, such as an invoice, for example, showing that recycling fees have been paid, is best.”

Ashley Bateson, principal of the sustainability group at building services consultants Hoare Lea, believes WEEE is a good initiative. For too long, UK landfill costs have been low, and this should force end-users to think again. He believes the cost per lamp will be minuscule compared with its overall cost. “I don’t think there will be a black market in lamps that are not [WEEE] accredited,” he says. “Reputable firms will always buy from reputable producers under the scheme.”

For luminaires, demolition and strip-out contractors must be WEEE-ready by July, says Ernest Magog, chief executive of Lumicom and immediate past director of the Lighting Industry Federation. It will be a big step forward from the current situation. “At the moment, to be honest, we’re not sure exactly what happens to the waste,” he says.

It is certain that contractors will pass on the additional costs of WEEE compliance schemes. Magog expects Lumicom to charge members a flat rate of £1 for disposal per lamp unit, but it is too early to give definite costs. He wants the costs to be much lower, but this will only be possible when there are more data on storage and treatment costs, as well as the costs to dispose of any hazardous waste.

Although fewer than 30 of the Lighting Industry Federation’s members are currently signed up to Lumicom, the other 320 UK producers will almost certainly have to do so unless they want to go it alone and pay their own costs, says Magog. Other lamp and luminaire compliance organisations have until 1 July to set up alternative schemes.

The Environment Agency expects the total number of recycling schemes to reach about 30 for all electrical and electronic goods. But at the moment, Recolight and Lumicom are the only answer to WEEE in the lighting world. “It’s a headache for producers,” says Magog. “So why not let us take that headache away?”

More information: www.recolight.co.uk; www.lumicom.co.uk