1.              Introduction

1.1              Electrical Safety First is the UK charity dedicated to reducing deaths, injuries and fires caused by domestic electrical accidents. The Charity does this through education, public awareness, advice campaigns and political engagement.

1.2              Electrical Safety First has a number of long-standing concerns about the manner in which electronic waste is dealt with in the UK.

1.3              The Charity believes there to be insufficient advice given to the public as to what should happen to waste electrical products, and that many potentially dangerous items are not properly disposed of, but in fact are resold without any safety checks being undertaken.

1.4              There are also concerns over the general handling of waste electrical products by Household Waste Recycling Centres (HWRC’s), operated by or on behalf of Local Authorities. Evidence collected by Electrical Safety First through an investigation in 2019 demonstrated that some Local Authorities are permitting the resale or donation of waste electrical products disposed of at HWRC’s, sometimes without any effective regime of checking to ensure the items are safe.

1.5              Electrical Safety First welcomes the opportunity to respond to this inquiry. The Charity supports the goals of establishing a proper Circular Economy, but in order for this to function properly for both the public and waste handlers safety must be a key concern.

1.6              Electrical Safety First has responded to three of the questions set out in the terms of reference, below.

For any comments or questions regarding this consultation response, please contact the Policy and Public Affairs team at Policy@electricalsafetyfirst.org.uk

2.              Answers to specific Inquiry questions

 

Part One: Implementing a Circular Economy for Electronic Goods

2.1              Ensuring safety must be key in any secondary market for electrical goods. In particular the following points must be addressed:

2.2              The commercial sale of any second-hand electrical products must be carried out only if

1. The product has been checked by a suitable competent, qualified individual, and has been declared safe for continued use

2. The product has been checked against a database of known product recalls and is not an affected model or has been suitably modified and made safe by the manufacturer, with proof available.

2.3              Whilst applying such restrictions to private (or “person-to-person”) sales is unrealistic, the main online sales platforms should be approached by Government with the aim of having the above requirements  adopted as guidance for those listing products for sale on their platforms.

 

Part Two: UK’s Electronic Waste Sector

2.4              Electrical Safety First investigated the way that different local authorities across the UK managed the recycling of waste electrical products, both directly in council-run facilities or through a contractor, in which 351 Local Authorities were questioned.

2.5              This demonstrated that there was no overall unified scheme for recycling, with almost every local authority which responded having a different scheme to that of their neighbouring authorities. The responses also revealed that where Local Authorities were reselling products from HWRC’s, only 6% of those who responded checked products to see if they had been subject to a product recall. It is extremely concerning that Local Authorities are selling second-hand goods, particularly white goods to the public without undertaking safety checks and looking for recalled items.

2.6              This being so, it is important that the UK government considers the need for a single, universal waste electrical recycling scheme, with as few variations between Local Authority areas as practicable, and where the safety of the public is prioritised.

This should involve:

1. All HWRC and other facilities accepting the same types of WEEE, regardless of location

              2. The same recycling pathways

3. Any items deposited as waste at a HWRC or similar facility judged suitable for resale must be tested for electrical safety and checked as to whether the product has been subject to a recall action

4. Communication to the public that their donated items are to be re-sold

 

2.7              Our work demonstrated that the overall picture of recycling across the UK was very varied, with no universal overall scheme for what can and cannot be recycled – and this extends to all waste, not just WEEE.

2.8              With such a variation between areas it is hard to see how the public can have a proper understanding of what scheme is being operated where they live, or if their nearest HWRC is in a different Local Authority area to where they live.

2.9              Public awareness can be improved in a fairly straightforward way by direct communication from the local council to the public, ensuring that the messaging is clear. For example, many councils already perform similar actions with details of what can and cannot be placed in a household recycling “wheelie” bin.

2.10              However this still leaves room for confusion if the schemes operated by Local Authorities remain different. Therefore, the most straightforward route to reducing confusion and increasing public awareness would be to ensure that all Local Authorities run identical schemes, as far as is practicable.

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