Potential Solution to the Problem

Friday, December 4, 2009
Since reuse is the highest order of recycling, inventory asset liquidation customers of some specialized, private marketplace auction services providers are already practicing a WEEE-compliant form of recycling (that is, reuse) by selling excess, refurbished, and returned products through their auction platforms. The disposition of product for secondary use prolongs the useful life of the product, thereby deferring the costs of recycling and netting cash to a company's bottom line; profit recovery is maximized through competitive bidding. The audit trail of products listed, products sold, and registered bidders can be included in the tracking and reporting of take-back and recovery programs. However, ensuring complete WEEE compliance is essentially a network management problem. It entails managing the collection of products via licensed carriers and the coordination of sorting and disposing of products within authorized facilities. It also includes managing the resale of products to ensure the highest possible recovery rate and tracking treatment through certified recyclers. Most manufacturers, recognizing that their core competence lies in product design and marketing, will elect to outsource compliance management to a partner organization or third party logistics (3PL) provider. To that end, a manufacturer can do one of the following:

* Establish a private take-back program, which would involve a manufacturer establishing a product recovery network consisting of specified drop-off and pickup locations, collection and transport networks, and remarketing and recycling partners. The network management may be administered in house or be outsourced to a service provider such as the company's 3PL. As an example, Dell Computer is an early leader in private take-back programs with door-to-door, consumer-level pickup of waste equipment at the time of new product delivery.

* Join a consortium whereby groups of companies may elect to join together to establish branded take-back programs. The operational coverage is essentially the same as that in a private WEEE compliance program, with the difference being that the member companies fund a joint operational entity to manage the network. A prominent Paris, France-based consortium is that of Braun, Electrolux, HP, and Sony, known as the European Recycling Platform (ERP). ERP chose as general contractors CCR, a German company that has dealt with automotive waste such as scrap metal, and Geodis, a French company with experience in IT take-back. Each company will handle selected EU countries, together providing a pan-European recycling operation.

* Join a national take-back program that will provide consumer-accessible collection points where a variety of products can be returned. Recycling is managed for the group by an internally appointed office, and the cost of recycling is borne by the member organizations, prorated according to their country sales volume by weight. Some good examples include NVMP in the Netherlands, RECUPEL in Belgium, Alliance-Tics in France, and Gambica and Repic in the United Kingdom (UK).

Whichever option a manufacturer chooses, it can envision the following three-step process to ensure an integrated and compliant inventory asset recovery:

1. Product Recovery, since manufacturers will be required to provide extensive networks for product recovery, from consumer drop-off to retailer, distributor, or municipal aggregation. As the manufacturer (or its agent) takes possession of the recovered product, the first capture of product category information should be completed, and related data stored in some appropriate WEEE compliance portal. The key tracking identifier in the portal would be the WEEE consignment note (WCN).

2. Controlled Product Disposition, since, whether on-site, in channel, or at a recycling center, the next step in the process is sorting, where the product is directed for resale or reuse, recycling, partial harvesting, or destruction. As appropriate, the WCN should then be broken down into sub-notes to ensure complete traceability.

3. Certified Destruction, whereby the product to be scrapped is routed to recyclers that are certified, registered members of the portal. As the product is disassembled and ground and components or materials recycled or salvaged, the relevant information would be recorded against the WCN(s). Certificates of destruction should then be stored within the database of the specialized, private marketplace auction services provider for auditing and reporting, whereby weight-in and weight-out transactions ensure data completeness to regulatory specifications.

As for proving compliance, compliance reporting of the required percentage of reuse and recycle will be aggregated by weight per time period. The provider of specialized, private marketplace auction services would store product weights cross-referenced to product categories for reporting and reconciliation. Whether reporting is aggregated by weight or detailed by product category, the compliance portal should capture the requisite source data in the three steps above. Combined reuse and recycling data would then be stored in the same database to simplify the reporting process and to ensure compliance with a minimum of overhead. The information generated should help the recycling company iron out collection inefficiencies in the short term, while on the other hand, it could affect product design in the long term for the manufacturer. One could imagine how useful feedback from the recycling facility could be, even if it is something as simple as a list of products that create the highest costs because they are hard to take apart.

Still, despite their existing solutions' fit, some private marketplace auction services providers have made the strategic decision to defer officially entering the WEEE space until the legislation is more clearly defined. In other words, they are taking a pause while the legislation evolves and the EU market matures, especially across the greater EU (let alone other, less environmentally friendly global regions). This is but a small reprieve for affected manufacturers and importers to "catch their breath." They should definitely start to devise strategies on how to comply at the end of the day, since it is only a matter of (not too long a) time before the WEEE legislation resolves any kinks it may currently have.

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