Strategically important metals - Science and Technology Committee Contents

Supplementary written evidence from Rt Hon David Willetts MP, Minister for Universities and Science, Department for Business Innovation and Skills (SIM 00b)


Thank you for inviting me to appear before your Committee on 2 March regarding strategically important metals.

I promised to respond to questions from Graham Stringer MP regarding the implementation and costs of the REACH and WEEE regulations.


Professor Robert Watson, Defra's Chief Scientific Adviser has already written to you explaining the primary aims of REACH, which is to enhance protection of human health and the environment, and to increase industry competitiveness and innovation. He argued that it is too early to say to what extent the aim of increasing industry competitiveness and innovation has been achieved; the first registration deadline was 30 November 2010, and the process is being phased in until 2018. It will be important to review the outcome of those first registrations and learn any lessons for the two further stages due in 2013 and 2018.

Defra will be conducting an in-depth national study later this year. This will inform their response to the European Commission's EU-wide review of REACH next year.

Sectors of industry joined together in consortia to provide the scientific data required to be generated for REACH registration. Letters of access to their data are a commercial matter between those in the consortia who have had to incur costs in generating the data and those seeking to use the data for their own products/purposes. Such arrangements would be subject to competition law, and could be investigated if there was sufficient evidence of anti-competitive practices. The OFT is responsible for enforcing competition law and has significant powers to investigate and act where it finds companies abusing a dominant position or behaving anti-competitively.

BIS worked alongside Defra on the REACH negotiations and we consider the regulations to be balanced and proportionate.


I am pleased to attach an extract from the Impact Assessment giving the costs and benefits of UK WEEE Regulations, as requested by Mr Stringer. I also attach the impact assessment of the European Commission's proposal to "recast" the WEEE Directive, currently under negotiation in Brussels.[59]

Department for Business Innovation and Skills

31 March 2011



1.  The cost of collecting, treating and recovering WEEE depends on a wide range of factors including the volume and composition of WEEE; the quality of WEEE; the value of materials in WEEE; and the means of collecting, treating and reprocessing WEEE.

2.  Discussions with a number of Producer Compliance Schemes (PCSs) operating under the UK Regulations suggest a range of costs for collecting, treating, and recovering different categories of WEEE. Though the UK Regulations apply across 13 categories of EEE, WEEE is usually considered in terms of five broad categories. These are: cooling appliances (Category 11—"Cooling"); large household appliances (Category 1—"LDA"); display equipment (Category 12—"Displays"); mixed WEEE (Categories 2, 3, 4, 5, 6, 7, 9, 10—"Mixed"); and gas discharge lamps (Category 13—"GDL"). The range of average costs we have received are shown in Table 1 below. The average costs we use are taken as the mid-point of these ranges.

Table 1

LDAMixed DisplaysCooling GDL
Average cost range (£ per tonne)10-20 120-180220-280150-185 1,500-2,000
Middle of average cost range (£ per tonne) 15150250 1681,750

3.  Using the middle of the average range of costs suggests that for the volume of separately collected household WEEE collected, treated and recovered in the UK in 2008, total costs were in the region of £58 million. It is recognised that the costs for non-household WEEE are more varied than for household WEEE and are therefore more difficult to "average". However, if the average costs in Table 1 reflected the costs for non-household WEEE, then the total costs for non-household WEEE separately collected in the UK in 2008 would have been in the region of £8 million.

4.  There were additional costs relating to the following: producer registration fees were in the region of £2 million; PCS administration costs were also in the region of £2 million (assuming an average charge of £400/producer); monitoring and enforcement costs (public sector costs) were in the region of £3 million; licences for approved treatment facilities (ATFs) and approved exporters (AEs) dealing with WEEE were in the region of £0.35 million; and costs under the Distributor Takeback Scheme (DTS) were in the region of £3 million (presuming the total costs of the DTS are spread evenly over three years). This gives an estimated total cost of the UK WEEE Regulations of just over £76 million in 2008.

5.  In terms of the benefits of the UK WEEE Regulations, there is less readily available information on the monetary value of these. The 2006 RIA estimated that the monetary value of climate change benefits from the additional separate collection, treatment, recycling and recovery of WEEE could be in the region of £4-16 million in 2008.

6.  In addition to this, there will be benefits currently from avoiding the possible leaching of materials and the possible emission to air of materials from diverting WEEE from landfill and incineration. These are, however, difficult to quantify in monetary terms in relation to WEEE specifically. The separate collection of WEEE in the UK is also likely to be contributing positively to sustainable consumption and production, and having positive "spillover" effects on other forms of waste and the issue of waste generally. These, however, are also difficult to quantify in monetary terms.

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