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A new horizon of business sustainability: A

comprehensive analysis of business

strategies and financial developments ESS
Recycling (UK) Ltd.

Company ChairmanMr Horacio Carvalho

Company Secretary- Mr Ramesh Radia
Managing Director- Mr Philip Wright

1. Introduction
a. Overview of WEEE industry in UK
b. Sustainable Business in Waste Electronics and Electrical Equipment (WEEE)
c. The prospective of WEEE in sustainable business development
d. Overview of WEEE categories in UK (13 Categories)

2. Components of WEEE Regulative- Who all are obliged to the

WEEE regulations?
a. Components of WEEE- Producers, Distributors and Consumers
b. Household vs Non-household WEEE producers
c. Producer Complaint Schemes (PCS)
d. Approved Authorised Treatment Facilities
e. Approved Exporters

3. Business to Business (B2B) WEEE operating strategy and model

a. Introduction to Approved Authorised treatment facility (AATFs)
b. WEEE producers registered under various PCS schemes
c. Business to Business WEEE business

4. WEEE statistical generation data in UK (Nationwide data) (2011)

a. WEEE generation data in UK
b. Civic amenity site collected- Households WEEE
c. Non- Household WEEE arising in UK
d. Non- Household WEEE delivered to AAFTs

5. Sustainable Business in WEEE, A multidimensional perspective of

WEEE management in Small to Medium enterprises (SMEs)
a. Research Methodology and Data resources

6. Sustainable Business development- Environmental Storage

Solution Recycling Limited (ESS Recycling Ltd)
a. Overview and Introduction of ESS recycling Ltd
b. Market analysis of ESS in the WEEE industry
c. People and Mission
7. Investigating the competitors and the market penetration
a. Direct and Indirect Competition analysis
b. Qualitative investigation
c. Quantitative investigation
d. Documenting the results
8. Analysing the Market distribution of WEEE and business development
a. Investigating the WEEE arising in general
b. Investigating the WEEE processed by the competitors
c. Building comparative model to investigate the company business strength
d. Building baseline business of ESS Recycling Ltd to compare with the

9. Financial analysis of the business

a. Investigating the financial reporting of the competitors
b. Analysing the financial developments and sustainability

SWOT analysis

Z analysis- Altman

Pitrovsky F score analysis

Comparative analysis of key financial parameters- Assessing financial


10. Future of WEEE developments and Policy implementation

a. Researching future WEEE market
b. Investigating the streamline of policy and legislation changes

11. Analysing Needs and evaluating options

a. Organisation modelling
b. Business process analysis
c. Identify options
d. Shortlist options
e. Prepare business case
f. Business change identification

12. Conclusions

a. Overview of WEEE industry in UK
b. Sustainable Business in Waste Electronics and Electrical Equipment (WEEE)
c. The prospective of WEEE in sustainable business development
d. Overview of WEEE categories in UK (13 Categories)

Impact on the British economy

Analysing the effectiveness

a. Overview and WEEE Directive
Environmental pollution, particularly in landfills, from discarded electronic equipment
(e-waste) or "waste electrical and electronic equipment" (WEEE), has been an
increasing concern worldwide. Pollution occurs due to leakage of hazardous materials
contained in the discarded equipment. The European Union has passed two related
regulations to improve e-waste management and to limit the presence of hazardous
materials in the waste.

One is the Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC.

This limits the presence of six hazardous materials in electrical and electronic

The other is the Waste Electrical and Electronic Equipment (WEEE) Directive
2002/96/EC. The WEEE directive aims at minimization of the impact of e-waste
on the environment, by increasing re-use and recycling and reducing the
amount of WEEE going to landfills (Defra, 2010a)

The Waste Electrical and Electronic Equipment (WEEE) Regulations (the Amendment
Regulations), which came into force on 1 January 2010, have been designed to reduce
the overall administrative burden on businesses by streamlining the WEEE system

implementing the main provisions of the European Parliament and Council Directive
on waste electrical and electronic equipment (as amended) (the WEEE Directive). The
WEEE Directive is one of a small number of European Directives (European Union,
The WEEE Directive is based on article 175 of the European Commission (EC) Treaty
which established the European Union that implements the principle of extended
producer responsibility. Under this principle, producers are required to take financial
responsibility for the environmental impact of products they place on the market,
especially when those products become waste. The WEEE Directive applied this
principle in relation to electrical and electronic equipment (EEE). This directive makes
producers responsible for financing the collection, treatment, and recovery of waste
electrical and electronic equipment. It also seeks to oblige distributors to allow
consumers to return their waste equipment free of charge. This provision is based on
the precept that the polluter should pay and applies irrespective of the selling
technique, including distance selling (Defra, 2010b).
The main aim of the WEEE Directive is to challenge inappropriate WEEE treatment.
WEEE is considered as the fastest growing stream of waste category in EU, which is
around 8.3-9.1million tonnes in 2005, and projected mount to 12.3 million tonnes of
WEEE by 2020. One of the main challenges in WEEE industry in reducing these figures
according the expert views who has the working experience within the industry as
stakeholders, Member states and scholars are that the Directives activities and
strategy plans to amend the new developmental scenarios and procedure to help the
considerable WEEE reduction scenario are very less exercised and at the level of infancy
in its activities. There are also criticisms raised on the cost-effectiveness of WEEE
Directive in delivering its recommendations (Phillips et al., 2006)

The WEEE Regulations is characterised by a number of associations for producers and

distributors (retailers) of EEE. These regulations do not exclude any business sectors
to be operative outside the policy and legislation boundaries which the small to
medium enterprises as well as big companies should be equally obliged to. In effect
the regulations are uniformly distributed to all the companies in EU. These includes
the EEE distributors to provide facility for take back service, free of cost from household
WEEE producers and final consumers, end users etc. .

This also covers the

environmental aspects of the sustainable WEEE processing depending on the costeffectiveness (Envirowise, 2009)

Figure 1: WEEE hierarchical strategy of treatment and reduction

b. Sustainable Business in Waste Electronics and Electrical

Equipment (WEEE)
An initiative from the UK Governments waste strategy 2010, sustainability is now a
central issue for business and society. Even among long-standing champions of
sustainability, the urgency of the debate has moved beyond the concern for future
generations to the here and now.
With the short liming factors of time and resources the attainability of sustainable
business has always been a challenge but the same time developed cost-effective and
skill based business strategies to achieve the goal. The central part of such a
developmental system is information. The Institute of Chartered Accountants in
England and Wales (ICAEW) mainly addressed the above denoted aspect of resource
and time based strategies which can address the challenges and impacts of such a
system which would encompass the development of the continuous chain of business
to environment and to the country (Lisa et al., 2010).

The reporting requirements of the business within the SMEs and other big companies
have been a major policy change in UK and EU. It is not the simple representation of
how the business can operate within a sector, but instead how the business can
address various developments that is the combined but balanced developments of
1. Social
2. Economic
3. Environmental
4. Institutional Frameworks
The requirement of greater transparency within any industries regardless of the size
and economic position is proved to be another mandatory requirement for the
achievability of the above mentioned objective. This has been widely supported by

ICAEW and the Environment Agency, as well as many other organisations. The value
based strategies, transparency in implementation of the protocols, accessibility to
business analysis using sustainability indicators, management outflow efficiency are
proved to the vital components in driving institutional investors and capital market
participants (WRAP, 2010).

c. The prospective of WEEE in sustainable business development

It has estimated that the market generation of WEEE in UK is around 222 million units,
each year. EEE being one of the mostly produced waste streams with the continuous
increase in amount about 16% to 28% each year for last five years starting from 2005.
This is considered as three times as fast as the growth of average municipal waste (1
million tonnes EEE per year) (Defra, 2009a).
The broad aim of WEEE Directive is to manage the environmental effects of EEE on its
end life cycle thereby enabling separating the WEEE from other waste streams,
followed by the treatment, re-use, and recovery and recycling and as the final option
environmentally friendly disposal of the end-products (Defra, 2009a). This processes
are also seek to improve the operative settlement of environmental performance of
the WEEE stream. The integration of main aspects of management, cost-effectiveness,
financial regulations and resource efficiency are the key elements of such a strategy.
It sets requirements relating to EEE in terms of the marking of equipment and the
provision of information for the separate collection of WEEE, re-use of WEEE as whole
appliances, standards for its treatment at specific facilities and recycling and recovery
to target levels. It makes the producers of EEE responsible for financing most of these

d. Overview of WEEE categories in UK (13 Categories)

Effective August 13, 2005, the WEEE directive, excludes equipment related to state
security, arms and ammunition and war materials However it does cover thirteen
categories of e-waste:
1. Large household appliances excludes ODS fridges/freezers
2. Small household appliances (e.g. toaster, kettle, vacuum cleaner)
3. IT and telecommunications equipment
4. Consumer equipment (e.g. videos, radio, hi-fi) excludes CRTs
5. Lighting equipment excluding fluorescent tubes
6. Electrical and electronic tools (e.g. drills, saws, sewing machines)
7. Toys, leisure and sports equipment (e.g. electric trains, video games)
8. Medical Devices excludes contaminated items
9. Monitoring and control instruments (e.g. smoke detector, thermostats)
10. Automatic dispensers (e.g. vending machines)
11. Cooling equipment including category 10 devices with cooling
12. Display equipment (CRTs) including plasma and LCD
13. Gas discharge lamps (e.g. fluorescent tubes)

Figure 2: Lifespan Distribution of WEEE (Source: WRAP, 2010)

Impact on the British economy

WEEE infrastructure to support the waste hierarchy and resource efficiency to enable
the sustainable waste strategy development and minimization of exponential growth
of WEEE has been the key action plans of Waste Hierarchical Plans, 2001. WEEE
compliance and the cost measures are given significant priorities in the new legislation
context within EU especially in UK which covers 455 million for all the companies to
comply with the directive in the waste management strategies of UK (ETBPP, 2009).

Analysing the effectiveness

After the establishment of WEEE Directive the significant changes in the pattern of
WEEE collection, disposal and re-use became very apparent with the support from
Governmental and non-governmental authorities, county councils, Environmental
agency, Defra, WRAP etc. This is characterised by the increase in global metal prices
and infrastructural and policy support to collect the WEEE from end-users, cutomers,
and consumers are encouraged. This has also put in place obligatory places for the
producers of EEE, distributers and re-branders to ensure the collection and appropriate
and environmentally sustainable waste disposal and treatment. This has resulted in
high amounts of WEEE being collected separately from domestic waste, with only an
estimated 13% of WEEE going to landfill or incineration (NRWF, 2005).
The indications are that there is separate collection over 85% of WEEE arising, even
though only 33% is officially reported as 'separately collected'. A large part of the
unreported, but collected, WEEE may either be treated in the EU without due
environmental care or illegally shipped to developing countries where parts of the
valuable material are recycled in ways dangerous to the health and environment, or
Based on current practice, this problem will grow rather than diminish, with an
estimated 4.3 million tonnes improperly treated each year by 2020, increasing from 3.4

million tonnes in 2005. The predicted destination and collection of WEEE in 2020 is
estimated below (Defra, 2010).

Figure 3: WEEE baseline scenario (Source: Business Link, 2009)


2. Components of WEEE Regulative- Who all are obliged to

the WEEE regulations?

a. Components of WEEE- Producers, Distributors and Consumers
b. Household vs Non-household WEEE producers
c. Approved Authorised Treatment Facilities (AATF) or Approved Exporter (AE)

a. Components of WEEE Regulative- Who all are obliged to the

WEEE regulations?
The Waste Electrical and Electronic Equipment (WEEE) Regulations affect almost all
businesses. The following categories in the business sector are obliged to perform their
activities under the WEEE regulations.
Components of WEEE- Producers, Distributors and Consumers

manufacture and sell EEE under your own brand

resell EEE products produced by another supplier under your own brand

import or export EEE into the UK or another European Union member state on
a professional basis

retail outlets

wholesale outlets

mail order

the internet

TV shopping channels

other distance-selling methods


Consumers have no legal obligations under the Regulations.

The Regulations encourage private householders to play their part in the

separate collection of WEEE when it is discarded as waste.

Consumers have the ability to deposit WEEE in specific areas at civic amenity
(CA) sites across the UK and in other specific collection facilities (Defra, 2011).

b. Producers of Non-Household EEE

The producers of non-household EEE may have an obligation to finance the costs of
collection, treatment, recovery and environmentally sound disposal of EEE.


obligation applies:

When discarded EEE was put on the market on or after 13 August 2005

When discarded EEE put on the market before 13 August 2005 is replaced with
new EEE

c. Approved Authorised Treatment Facilities (AATF) or Approved

Exporter (AE)
c. AATFs and AEs deal with separately collected non-household WEEE.
d. AATFs and AEs also deal with household WEEE arising at DCFs or via Regulations
32 [and 39] of the Regulations on behalf of Producer Compliance Schemes
(PCSs) (WRAP, 2011).


3. Business to Business (B2B) WEEE operating strategy and model

a. Introduction to Approved Authorised treatment facility (AATFs)

What is an approved authorised treatment facility (AATF)

b. WEEE producers registered under various PCS schemes

Business to Business (B2B) WEEE operating strategy and

a. Introduction to

Approved Authorised

treatment facility

The Waste Electrical and Electronic Equipment Regulations 2006 (SI3259) (the WEEE
Regulations) s include targets for the amount of waste electrical and electronic
equipment (WEEE) that will need to be treated, recovered and recycled. Sites that treat,
recover and recycle or export WEEE will need to be approved. They will play a crucial
part in providing evidence that different categories of waste have been treated and
Each and every business irrespective of its size and operation has the legal obligation

Treats household WEEE taken from designated collection facilities or


Treats non-household WEEE taken from designated collection facilities,

distributors or end-users

Exports WEEE for treatment, recovery and recycling inside the EEA

Exports WEEE for treatment, recovery and recycling outside the EEA

Refurbishes whole electrical or electronic appliances

Holds an appropriate waste management licence, PPC authorisation or

registered exemption for treatment of WEEE

The approval system will enable a consistent approach to treatment facilities and
exporters and ensure that evidence of treatment, recovery, recycling is standardised
across the UK. It will also allow us to effectively monitor the treatment of WEEE
undertaken at approved authorised treatment facilities (AATFs), and the subsequent
recovery and recycling of WEEE, which takes place in the UK. We will also be able to
monitor approved exporters (AEs) to ensure that exported wastes are treated,
recovered and recycled to equivalent standards to those required in the UK (WRAP,
What is an approved Authorised Treatment Facility (AATF)?
An authorised treatment facility (ATF) is a licensed (or registered exempt) site carrying
out treatment on waste electrical and electronic wastes.

Treatment can include

depollution, disassembly, shredding, recovery or preparation for disposal.


operator of a site or sites receiving WEEE direct from a designated collection facility
(DCF), distributor or end-user can apply to become approved. Only operators of
approved ATFs (AATFs) can issue evidence notes for the treatment, recovery or
recycling of WEEE that takes place in the UK

b. WEEE producers registered with PCS Schemes

WEEE producers (5191) registered members are operating under various PCS schemes
are categorised under 39 PCS Schemes either in B2B or B2C compliance schemes or

Table 1: WEEE producers registered under Producer compliance Schemes (PCS)

Compliance Scheme

Total WEEE Producers are registered with

A1 Compliance


Accerio WEEE Scheme


Advantage Waste Brokers Ltd


B2B Compliance




Budget Pack


City Compliance Scheme

Compliance 4 U Ltd


Comply Direct Limited


Dataserv Compliance Services

DHL WEEE Compliance


Draeger Medical UK



Electric International Ltd







Lumicom Ltd


Northern Compliance


Recolight Limited


Recycle 1st


Recycle Telecom Producer Compliance 6






Servis WEEE

Shields Environmental PCS





Veolia ES WEEE Compliance Scheme 122

(UK) Ltd
WE3 compliance


WEEE Compliance UK








Source: Environmental Agency, (2011)


Chart 1: Representation of top WEEE producers (Source: EA, 2011)

The analysis of the data shows that, 3273 B2B WEEE compliance schemes are registered
with PCS schemes and 1181 B2C WEEE producers are registered to PCS and other 732
WEEE producers with B2B and B2C obligation is also registered with different 39 PCSs.
Table 2: B2B and B2C number of WEEE producers
Grand Total
Source: EA, (2011).



WEEE statistical generation data in UK (Nationwide data) (2011)

a. WEEE generation data in UK
b. Civic amenity site collected- Households WEEE
c. Non- Household WEEE arising in UK
d. Non- Household WEEE delivered to AAFTs

WEEE statistical generation data in UK (Nationwide data) (2011)

The EU WEEE Directive (2002/96/EC) currently sets a minimum collection target of 4
kg per annum per inhabitant for WEEE from households. A proposal has currently been
submitted to alter the collection target from 4 kg per annum per inhabitant to a 65 %
collection rate, calculated according to the average amount of WEEE placed on the
market in the two preceding years. In addition, in order to encourage the re-use of
whole appliances, it is proposed that such re-use be included within the 65 % target.
Use of hazardous substances in WEEE is restricted by the Directive on the Restriction
of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment
(RoHS) (Directive 2002/95/EC). It also requires heavy metals (for example lead, mercury
and cadmium) and flame retardants (for example polybrominated biphenyls (PBB) and
polybrominated diphenyl (PBDE)) to be substituted (Strategic Waste Management
Assessment, 2000).

Chart 2: WEEE figures with prediction projections (Source: Phillips et al., 2008)
In the explanatory memorandum of the WEEE Directive, the amount of EEE arising as
waste was estimated in 1998 for the EU15 at 6 million tonnes. The new estimate of the
current WEEE arisings across the EU27 is between 8.3 and 9.1 million tonnes per year
for 2005. This increase is due to expansion of the EU, growth in the number of
households and inclusion of items that may have been excluded previously (B2B). A
number of forecasting assumptions were applied which predict that by 2020, total
WEEE arising will grow annually between 2.5% and 2.7% reaching about 12.3 million
tonnes (Environmental Agency, 2011). The average compositional breakdown for the
EU has been calculated and shown in the figure below:

b. House hold WEEE Collected by Councils, CAs in UK during the

time of January 2011- September 2011
Category Name














from a DCF1 under







322 (tonnes)

393 (tonnes)











Household 23,745.194



Household 6,598.950


IT and Telcomms 7,166.586








Lighting Equipment 0.000















and 5.615








and 3,536.214

Electronic Tools

Toys Leisure and 423.826


Medical Devices





Display Equipment






Cooling Appliances













Discharge 183.277



Non- House hold WEEE Collected by Councils, CAs in UK during the

time of January 2011- September 2011


Household 65.562




Household 23.452








Telcomms 992.972


Consumer Equipment




Lighting Equipment




Electrical and Electronic 57.486




Toys Leisure and Sports




Medical Devices




Monitoring and Control 16.597




Automatic Dispensers





Display Equipment








Appliances 909.738

Containing Refrigerants

Gas Discharge Lamps








Non- House hold WEEE Collected by Councils, CAs in UK during the

time of January 2011- September 2011







House-Hold Waste Electrical and electronic Equipment (WEEE)

received at an Approved Authorised Treatment Facility (AATF) from
January 2011 to March 2011


Large Household Appliances

Small Household Appliances
IT and Telcomms Equipment
Consumer Equipment
Lighting Equipment
Electrical and Electronic Tools
Toys Leisure and Sports
Medical Devices

Household Household Household

For Reuse Sent to
1,258.967 10,131.027


Monitoring and Control

Automatic Dispensers
Display Equipment
Cooling Appliances Containing
Gas Discharge Lamps










129,326.430 12,470.469




Received for Treatment

For Reuse
Sent to AATF/ATF

Non- House-Hold Waste Electrical and electronic Equipment (WEEE)

received at an Approved Authorised Treatment Facility (AATF) from
January 2011 to March 2011


Large Household Appliances
Small Household Appliances
IT and Telcomms Equipment
Consumer Equipment
Lighting Equipment
Electrical and Electronic Tools
Toys Leisure and Sports
Medical Devices
Monitoring and Control Instruments
Automatic Dispensers
Display Equipment
Cooling Appliances Containing Refrigerants
Gas Discharge Lamps

For Reuse

Sent to



Non-Obligated Waste Electrical and electronic Equipment (WEEE)

received at Approved Authorised Treatment Facilities (AATF's) &
Approved Exporters (AE's) from the period of January 2011 to March



Large Household Appliances

Small Household Appliances
IT and Telcomms Equipment
Consumer Equipment
Lighting Equipment
Electrical and Electronic Tools
Toys Leisure and Sports



Medical Devices
Monitoring and Control
Automatic Dispensers
Display Equipment
Cooling Appliances Containing
Gas Discharge Lamps


Chapter 5
Sustainable Business in WEEE, A multidimensional perspective of WEEE
management in Small to Medium enterprises (SMEs)
a. Research Review: An insight into the Financial and Management sector of
Research Methodology and Data resources

Sustainable Business in WEEE, A multidimensional perspective of WEEE

management in Small to Medium enterprises (SMEs)
a. Research Review: An insight into the Financial and Management
sector of WEEE
The direction of this research was steered in response to advice from the panel of WEEE
experts from Environmental agency, Business and Innovative Skills and Manchester
University Database, Sustainable community Business Development.
Some of the areas investigated included:

1. General internet searches

2. MINTEL market research
3. ACORN database
4. Trade press
5. British Library searches
6. University of Manchester
7. University of Northampton Data Base
8. Academic journals

b. Research methodology
Factors as size, market sector, geographic location, and turnover, and ethnic origin,
type of property, age, sex and religion have all been studied and reported many times.
However, none of this information included a direct link between one of these factors
and the ownership of electrical and electronic equipment. This lack of data related
specifically to WEEE arisings and details of Approved authorised treatment facility,
Producer Complaint Schemes and other related components in the WEEE processing
and recycling makes it difficult to assess the progress of WEEE management.
The Industry Council for Electronics Recyclings (ICER) estimate of approximately one
million tonnes of household WEEE generated in the UK annually has become the
benchmark figure used throughout the industry.


Sustainable Business development- Environmental Storage Solution

Recycling Limited (ESS Recycling Ltd)
a. Overview and Introduction of ESS recycling Ltd
b. Company Profile and Activities
c. Growth analysis of WEEE business of ESS- A comparative analysis
d. People and Mission

Sustainable Business development- Environmental Storage

Solution Recycling Limited (ESS Recycling Ltd)
a. Overview and Introduction of ESS recycling Ltd
ESS Recycling (UK) Limited has been the leading market holders of WEEE recycling and
is best in the recycling, re-use and disposing of WEEE in environmentally sustainable
methods. The company has its longest established credentials and quality in UKs WEEE
market and is independently owned recyclers of end of life refrigeration, air
conditioning, electrical and electronic waste contained within the WEEE directive (ESS

Location of ESS (UK) Limited, Google Maps

b. Company Profile and Activities

ESS has a long history of 11 years of WEEE service in UK market and has been the
leading operatives in the whole sectors of WEEE processing. The company has proved
its potentials not only in conducting the WEEE recycling and disposal, but also in
carefully aligning with the environmental regulations as well as resource efficiency
business adoption. Established in 2000 with a state of art facility based in
Northamptonshire, ESS demonstrated the different dimensions of sustainable business
in very successful level. Even though the company has a strong affinity for specialist
refrigeration and vending recycling, the whole WEEE sector are processed in an
efficient manner. Highly skilled management, workers, logistic and other key drivers
are the core part of the company. ESS is licensed for all13 Categories of WEEE (Waste
Electrical and Electronic Equipment) since 2005. In 2006 ESS established the WEEE
Compliance Scheme, "Compliance 4 U".
In a long run history of ESS, the demonstration of modern recycling modern recycling
and degassing equipment has been one of the companies credentials in which the

other market competitors are still falling back. This along with a new comprehensive
AATF Licence highlights the ESS to its extreme levels of achievements. People and
management have been at its best for ESS. Highly skilled and experienced
management, logistic department, financial analysts, sufficiently trained and skilled
engineers and IT, are the core of the WEEE business in ESS
ESS (EAWML 100113), since 2000 has raised as successful leaders of WEEE recycling as
an AATF with a fruitful business spread to household and non-household WEEE. Few
of the other main developmental scenarios of ESS has been marked by the expertise
in the disposal of hazardous wastes, in particular ODS recovery and disposal using
condensation techniques.
Since 2007 ESS has been operating an Authorised Approved Treatment Facility (AATF)
at its recycling facility in Northampton, the East Midlands. Through a variety of material
recovery processes and strategic reprocessing partnerships, ESS has been providing
high quality evidence to producer compliance schemes across the UK in line with their
overall period targets.
Various WEEE services such as secure I.T. storage and data destruction, recycling and
disposal of commercial refrigeration, degassing, resource recovery etc. are offered by
ESS in its highest quality. Recovery and reprocessing of materials is consistently in
excess of the governments required levels making ESS a reliable network tool for
compliance schemes and their members.
The following are the categories of WEEE processed in ESS
Refrigerated Products:

Commercial, Industrial and Domestic refrigeration

Vending Equipment

Refrigerated Display Equipment


Water Coolers

Bar and Cellar coolers

Ice Makers

Cold Rooms

Electrical and Electronic Products

Automated Vending Machines

White Goods and Domestic Appliances

CRT and Flat Screen monitors and Televisions

Computers, Laptops and IT Equipment

Commercial Catering Equipment

Retail Point of Sale Equipment

Medical and Scientific Products

Leisure Products and Toys


Other Services

Fluorescent Tube and Lamp Recycling

Secure Recycling of Brand/Commercially sensitive products.

Secure Destruction of Computer hard drives (On or off site service)

Cardboard Recycling

Asset Reports

c. Growth analysis of WEEE business of ESS- A comparative


d. People and Mission

Horacio Luis De Wright- Chairman

Mr. Horacio Luis is the designated chairman of ESS (UK) Ltd. Mr. Horacio being an
international multitalented expert having proven experience and skills in various
sectors adds to the success of ESS with his commitments, leadership and ensures his
presence and guidance for all the growth of the company. Having a wide but deep
knowledge in environmental management issues and developments in policies and
legislation gained from his highly professional expertise working within Carbon
Emission and Trading in Portugal as well as in United Kingdom, he is able to provide
the company with resource and networks for developments with which ESS has always

Ramesh Radia - Secretary & Financial Controller

With vast expertise and experience in financial and management sector, Mr Ramesh
Radia has been an outstanding asset for the company. With cutting edge knowledge
in organisational character and management, he has been nourishing the financial
sector of the company. As one of the major shareholders and senior management
executive, Mr Ramesh has been implementing financial strategies and assessing the
growth measures of the company thoroughly and efficiently, which made the company
growth in the field of sustainable business development

Philip Wright - Managing Director

Following a period of consultancy in 2009, Philip joined the Board of ESS as Managing
director in January 2010. Philip has 25 years of experience in the metals recycling sector,
procuring and trading recycled products on a global basis.
Throughout his career Philip actively targeted material produced from the refrigeration
industry both before and after the implementation of the WEEE directive.

Adam Philpot - General Manager

Adam's career with ESS has spanned 8 years since he joined ESS in 2003 on a youth
employment scheme.
Since joining ESS, Adam has succeeded in gaining AAT technician level in accountancy and
has also achieved qualification to level 4 WAMITAB. Adam has made continual progression

within ESS, which with his extensive industry knowledge, lead to his promotion to General
Manager in 2010.

Kelly Ryan - Key Account Manager

Kelly has been with ESS since 2004 and has progressed within the company to her current
senior position as Key Account Manager.
Amongst her long list of responsibilities, Kelly schedules and organises service requests
for our key suppliers and ensures that the audit trail for their products is accurate and up
to date.

Lucy Helsdown - Logisitics/Administration

Lucy joined ESS in 2008 after gaining experience in the IT recycling industry. Lucy controls
the logistics and documentation which ensures our suppliers receive only the highest
levels of service.

1. Investigating the competitors and the market penetration

Direct and Indirect Competition analysis
ESS has been one of the top listed WEEE recyclers and is considered as the potential
leaders in WEEE recycling market in UK. With the business distributed equally to
household and non-household businesses, ESS has a very huge market competition in
the WEEE. With the proper managerial chain and other beneficiary factors, ESS is
rooted well on the centre of the market with environmentally sustainable practices
spreading the message of sustainable business.
Based on the calculations and statistical figures of Environmental Agency the following
list has been made which indicate the competitors of ESS (Environmental Agency,
Company Names (Approved Authorised Treatment Facility)
1. Absolute recycling Ltd
2. Aqua-force Ltd
3. ASM Ltd
4. Areani Ltd
5. Acorn Ltd
6. Aquaforce Ltd
7. BW riddle
8. Bell Microsystem Ltd
9. Benku Ltd

10. Balcan Engineering Ltd

11. Blue sky Ltd
12. BR Environmental service Ltd
13. BSX Ltd
14. BTR Ltd
15. CA recycling Ltd
16. Centillion
17. Computer display UK Ltd
18. Computer Recycling Technologies Ltd
19. Computer waste Ltd
20. Cooler Ltd
21. CRT recycling Ltd
22. Dataserv Ltd
23. Dexreco Ltd
24. Electrical waste recyclers Ltd
25. Emr recycling
26. Energy
27. Ltd
28. Environcom Ltd
29. Environmental concern Ltd
30. eReco EMEA Ltd
31. Foreman Recycling Ltd
32. Genuine solution UK Ltd
33. Greencyc Ltd
34. Manga Fu Ltd
35. MDJ light brothers Ltd
36. Mercury Recycling Ltd
37. Northwest electronic recycling center Ltd
38. Nil recycling

39. Overtone recycling Ltd

40. Recycling lives Ltd
41. Recycle Telecom Ltd
42. Recyclite Ltd
43. Recycling Ltd
44. Ripon Recycling Ltd
45. Ron Hull Junior Ltd
46. Sanak venture recycling Ltd
47. Scout Enterprises Ltd
48. Secure IT disposal Ltd
49. Shield Environmental PLC
50. Sims Ltd
51. Specialist Computer Holding Ltd
52. Stone Computers Ltd
53. TCG Global Ltd
54. The electronic waste company Ltd
55. Triple E Recycling Ltd
56. Trojan Electronics Ltd
57. The sofa project
58. United Recycling Ltd
59. Viridon Ltd
60. Waste Technique Ltd
61. Waste IT Ltd
62. WEEE 3 Ltd
63. We 3 Recycling Ltd
64. WEEE environmental GB Ltd
66. Wiser Recycling Ltd
67. XPO IT Services Ltd

68. Yorwaste Ltd (Company List.xls)

Section needs to be completed
Qualitative investigation
c. Quantitative investigation
d. Documenting the results
2. Analysing the Market distribution of WEEE and business development

a. Investigating the WEEE processed by the competitors

b. Building comparative model to investigate the company business strength
c. Building baseline business of ESS Recycling Ltd to compare with the competitors

Financial analysis of the business
a. Investigating the financial reporting of the competitors
b. Annual Financial Reporting requirements of AATFs
c. SWOT analysis- general details


Risk profiles

d. Financial assessments and market projection of ESS with the competitors

SWOT analysis

Z analysis- Altman

c. Comparative analysis of key financial parameters- Assessing financial stability

Sustainable Business of WEEE- An over view of financial reporting

and growth assessment
Financial developments based on the environmental responsibilities are very
prominent for WEEE business. This stresses on the integration of environmental issues
with the financial reporting framework to allow financial statements to make economic
decisions regarding environmental impacts on assets, liabilities, income and
expenditure; it can also reveal business opportunities, as well as offering a more holistic
approach to risk management. This could result in enhanced profitability, reputation
and relationships with employees and customers. As stated previously the need of
greater transparency, value drivers and sustainable indicators of environmental
commitments and need of effective management are the various fields in which the
developments must be clearer for the betterment of developments. The ICAEW and
environmental agency emphasises on such an improvement to expand the flow of
information to all users, particularly institutional investors and capital market

a. Investigating the financial reporting of the competitors

Environmental commitments have recently received huge attention in a business
setting. The legislation and policy regulation, there in has developed to drive and
support the baseline strategy of environmentally responsible business development
1. Socio-economic
2. Environmental
3. Institutional aspects

The main UK legislation and regulations support the multi-criteria decision taken
together to support water, air and waste streams and their operations to evaluate the
appropriateness of working procedures. Taken together, these directives cover the full
cycle of all business products and services and apply the principle of extended
producer responsibility

b. Annual Financial Reporting requirements of AATFs

The Companies Act 2006 clarifies the responsibilities of a company in fulfilling its
obligation towards environmental sustainability by addressing the following concepts
1. The company must produce a business report regardless of its size, operational
strategies. Business sprawls etc. (Companies Act 2006).
2. The business report should emphasize on the environmental commitments as
well as resource based economic sufficiency.
These can be summarised as following (Extracted from companies Act, 2006)
According to the Companies Act, the business review should contain:
(a) a fair review of the companys business, and
(b) a description of the principal risks and uncertainties facing the company.

In a review of environmental disclosures in the annual reports of FTSE, Environment

Agency in October 2007 found that 98% of the companies reviewed addressed
environmental issues in some way in their annual report for 2006/2007. However,
disclosure of this information was often of a broad narrative nature rather than
incorporating key performance indicators and was more frequently to be found in an
operating and financial review than in a business review. Only 15% of companies
reported quantified data in accordance with government guidelines, providing an
absolute figure that applies to the whole company.

The Companies Act 2006 states the importance of quantified business data for the
companies on annual basis which should include the following components
(a) Analysis using financial key performance indicators, and
(b) Where appropriate, analysis using other key performance indicators, including
information relating to environmental matters and employee matters.
(c) Operating and financial review (RS 1)
(d) Supporting implementation guidance includes examples on spillage, emissions and

The business report produced on the basis of the above mentioned settings must also
recognise environmental risks, uncertainties and opportunities. The need to include
KPIs is explicitly noted in the Act: The review must, to the extent necessary for an
understanding of the development, performance or position of the companys

Analysing the financial developments and sustainability- ESS an


SWOT analysis of WEEE industry

The SWOT analysis presented here is the general challenges the industries and
companies encounters during its operational phases and development of new
scenarios for business expansions, economic recovery, and market penetration. The
more specific analysis of SWOT can only be studied in detail on the estimated figures
of WEEE data is available for interpretation. This is necessarily a literature research
based analysis of WEEE strengths, weaknesses, Opportunities and Threat analysis.









implementation of the recommendations.

Basis of SWOT analysis and Business model development
The above mentioned general fact key elements which are considered in SWOT
analysis is given below
a. Risk profile of the project
b. Financial Viability of the project
c. Consumer Behaviours

Risk Profile

In order to achieve the analysis of SWOT related to ESS the following business model
has been consulted (The model is developed by Anglia-Ruskin University)

Based on this business models various sectorial threats are identified and analysed,
then further with discussing about the opportunities either to diminish the risk of effect
or to overcloud the risk with financial achievements. These analytical figures are then
investigated to produce the opportunities and threats. These can then be linearly
transferred to the SWOT analysis of ESS.

c. Financial assessments and market projection of ESS with the

ESS recycling (UK) limited is assessed to be establishing financial stability for the
forecasted 10 years line. This has been investigated from the assessment of companies
financial performance by benchmark analysis of financial forecasting. This investigation
has also indicated that, with the implementation of detailed business strategic plans
supported from the SWOT estimation and other proposals and major policy changes.
The future government underlines significant changes in the policies and legislations
associated with the WEEE recycling and market. Further detailed studies into the policy
changes and development of action plans to make better use of the changes to
develop business can be ideal choice. Under these circumstances the following
financial growth is anticipated

From the analysis it is very sure that, ESS can be potentially ranged among the Rocket
ship companies in the list. These companies even though can be considered as the
strongest opponent of ESS, with pragmatic and properly developed strategic plans, a
high boost in market penetration and capturing can be established.
This has also lead to the attention of developing sustainability in business to cop up
with the growing attentions of resource efficiency and financial indicator development
based on sustainable levels. The economic and business indicator development with
the help of multiple criterions decision making (MCDA) can be an optional but realistic
tool for the company to evaluate
1. Its developmental scenarios
2. Estimating progress and flaws of the development
3. Benchmarking the performance with leading competitors
4. Investigating the business change for the development

Below represents the financial indicators frame work developed in last 12 months
performance level. This indicator after careful selection can be applied across
1. 10 years of financial and business growth
2. Across sectors of growth
3. Regions of operations to study competitors

Volatile sector analysis (Category of WEEE analysis)

This has been very significant in identifying the companys performance in category
recycling effectiveness. The weakest or slow growing sector can be identified to build
plans to bring them back on track as well as analyzing the market generation of
particular category to investigate the changes needed to concentrate on the

Distribution of WEEE across the UK (WEEE available to AATFs) a

geographical representation
The following figure represents the geographical distribution of WEEE in UK. The WEEE
available geographically to number of AATFs in UK

Further details of financial measures of ESS Recycling (UK) Ltd

Profitability ratio

Z-Altman Scores- Financial stability

WEEE sectors and AATFs are always prone to financial instability and loss. There is
always a close linear relation between companys financial performance and market
penetration. As the growth and advancement of the company has a direct infliction on
the economic operation and saturation, it has always been important aspect to
compare and calculate Z scores to identify the strengths of the company and reference
these strengths with competitors.
The financial data used are annual and cover the period of 1999-2010. To compute the
market value used, we take the market value of the company on 31 December of each
year. The prices were taken by EFFECT S.A. database and on analyzing 63 competitors
33 of them found to be having financial instability over the last 5 years of periods

This instability can be resultant of recession and other inflations of the market. But the
correlation coefficient with
Ceff*= +-0.5 variation showing the market significant impact ratio, indicates that, the
inflation ratio is not sufficient to address the lowering of Z score, pointing the alarming
situation of the companies to investigate further on the scenarios where development
is required.
Examined model
The most well-known quantitative model for predicting bankruptcy is Altman's Zscore, which was developed in 1968 by Edward I. Altman, professor at Stern School of
Business. The Z-score is a set of financial ratios in a multivariate context, based on a

multiple discriminated model, for the firms where a single measure is unlikely to
predict the complexity of their decision making or the scope of their entire activities.
Altman examined a list of twenty two possible ratios, and finally has chosen five that
had the best results when they were applied together were selected after numerous
tests for the function. This model was later modified to the Altman (1993) model that
uses the same variables multiplied by different, however, factors.

The discriminant function is:

Z = 1.2X1 + 1.4X2 + 3.3X3 + 0.6X4 + 1.0X5
Given that
X1 = Working Capital / Total Assets, (WC/TA)
X2 = Retained Earnings / Total Assets, (RE/TA)
X3 = Earnings Before Interest and Taxes / Total Assets, (EBIT/TA)
X4 =Market Value Equity / Book Value of Total Liabilities, (MVE/TL) and
X5 = Sales / Total Assets, (S/TA)
Altman defined a grey area which is between 1.81 and 2.99. Firms, with z-scores
within this range, are considered uncertain about credit risk and considered marginal
cases to be watched with attention. Firms with Z scores below 1.81 indicate failed firms.
Although, the cut-off point was set at 2.675, Altman advocates using the lower bound
of the zone-of-ignorance (1.81) as a more realistic cutoff Z-Score. So if Z < 1.81, then
the company has a high probability of default. On the other hand, the company is
solvent, meaning that it is financial healthy. Some credit analysts, private underwriting
agents, financial analysts, auditors and firms themselves were concerned that since the

original model requires stock price data (X5), it was only applicable to publicly traded
The following figure shows the Z score flow for the general WEEE industries

Financial instability projection of ESS

The following figure shows stability trend line of ESS in financial growth with base
ground market development.

Even though the trend line shows that ESS has not been very much affected with
market fluctuation, there is a downtrend in the overall growth by 18% when compared
to the previous years. This downtrend can again be the reflection of overall market

SWOT analysis specific to ESS Recycling (UK) Ltd.

Analysis of the business environment is extolled as a fundamental part of the strategic
management planning process. In making sense of such analysis, consultants, business
schools throughout the world and textbooks propose the use of the SWOT framework
(Strengths, Weaknesses, Opportunities and Threats analysis) to practicing managers
and business and management students as a precursor to strategy formulation,
managerial decision making and action. As a framework, SWOT analysis is highly
commended for its simplicity and value in focusing attention on key issues which affect
business development and growth. It there- fore has the potential to become a
significant tool in identifying the factors which are most likely to influence a firm's
strategy and success. Yet its very simplicity can be its downfall.
Although many will be familiar with SWOT, it is felt necessary to provide a brief
overview. It is significant that the limitations of SWOT analysis tend not to be
considered and elucidated by many authors although such shortcomings are, perhaps,
the reasons why authors such as Aaker (1992), O'Shaughnessy (1988) and Greenley
(1986) do not emphasize the use of the SWOT framework in the first place.
While recognizing some of the limitations of SWOT analysis, the paper also
acknowledges its benefits, the value of which is not only seen in its outputs (which may
be used in the development of sound strategic business plans) but also in the very
process of carrying it out. Highlighted are the extra benefits to be gained in the use of
SWOT not just as a static analytical tool which helps generate an under- standing of
business activity but, also, as a dynamic part of the management process which can

actually facilitate management development and which can be harnessed to the

advantage of all involved. It can be seen as a valuable management tool which may be
easily absorbed with good effect into the realities and practicalities of an organization's
existing planning and strategy formulation processes.
Businesses seek survival, improvement and success. To fulfill such outcomes,
management planning and decision making require information about business
operations and the circumstances which surround them; such information is the basis
upon which business decisions may be made. By monitoring the business environment
it is possible to gain a view of the market and competitive position of the business. If
no such activity is under- taken, businesses increase their risks to a point where their
very survival may be in jeopardy.
So-called `environmental scanning' and `environmental analysis' (although many may
use alternative terminology) are considered such a fundamental and basic part of the
business planning process that the need to carry them out is accepted without
There are few, if any, who would deny the inherent value of, and necessity for, an
understanding of the business environment as a precursor to management decision
making although there is only mixed evidence to suggest that businesses carry out
such environmental `auditing' very well.
SWOT analysis which is conducted to produce a simple listing output is, frankly,
inexcusably inadequate. In practical terms, a serious risk is taken if the SWOT is left at
this naive level. It may be considered inherently dangerous because a false sense of
confidence in its findings may be created which in turn may lead to poor management
decisions and action. While consultants and academics extol the virtues of SWOT
analysis and recommend its use in the early stages of business planning (e.g. Piercy,
1991; McDonald, 1992; Field, 1992; Carson et al., 1995), descriptions of SWOT analysis
typically do not address the problems and limitations which are often experienced in

its use. This is a great pity as most of these difficulties can be overcome quite easily,
resulting in a greatly improved piece of analysis with the added benefit of enhancing
management development.
Experience with managers on business and management programs and `action' research within organizations has revealed inherent limitations in the practice of
`SWOTing' both in terms of the processes involved and in its output. In the case of the
former, this is addressed below in the section `SWOT analysis as a management

SWOT Analysis
Strengths of ESS
1. Continuous and sustainable financial growth is the major advantage of ESS and
it has been considered as one of the major strengths of the company. The Z
scores level analysis states that, the ratio of financial instability of ESS is very
low even when the market level instability is very high. This establishes that,
once the inflation level would be recovered ESS will be hugely advantaged. The
growth of the company has been also sustainable when comparing with the
fluctuated growth of other competitors on the same sector. This is particularly
important to consider as the management and chain of operation has
continuously operated in its effectiveness to drive the change to a positive

2. This above mentioned sustainable growth is something that the whole idea of
how the business should develop.
3. Greater support with the policy and environmental regulation- With the support
of all regulations and policies, the clients or the customers will have no doubt
to trust ESS
4. Great integrity and operative principles of micro and macro components of

1. Even though the company started operative 10 years ago in 2001, the failure to
establish a PCS scheme yet is considered as a weakness. This is very prominent
as the new legislation changes eyes on AATF run by PCS of its own human
resources to improve the opportunities of

stakeholder dialogue, greater

transparency, greater accessibility to development and stronger inclination to

environmental practices
2. The long run of ESS was characterized by the lack of significant market
penetration. Even though the marked level of sustainability can be seen in its
growth, the recent financial growth data directs to the market penetration
3. Frequent assessment of business and financial development is another key
factor for the business. A business has to demonstrate that, the regular
investigation should never be confined to daily reporting of sales and returns
and processing, but also should be able to define the parameters of financial
and business development on a regular basis. In essence the need of business
analyzer and developer must be present in the company to help in the long run
of overall development and analyzing the strategy to propose new resolutions

1. There are a huge number of opportunities present for ESS for both the
sustainable and market development. These all are closely aligned with the
following factors

An over look into the strategic development plans for the future

Design the new business plans with clear mention about efficient

Daily investigation of business development (Analysis)

Developing economic and developmental indicators and benchmarking

them with the time and other competitors

Delivering and applying the indicators on a regular basis for the


Work as pro-active group to build and develop new business plans with
regard to changing policies and legislation

Be prepared for the boom of the market underlined by clear cut

planning. Unplanned operations in the future or relying on the traditional
style of business development will end up in a heavy blow

1. For all the reasons competitors are the biggest threats for ESS. In this daily
competitive sector, in order to achieve development in the business there must
be a very clear scenario from the base of strategies must be written. The main
assumptions can be extracted from Weaknesses, strength, and opportunities to
develop protocols for development and tackling the huge market competition.
Utilizing the best strengths as mentioned above the weaknesses can be
addressed from which new opportunities can be identified and measured
2. Another threat is the upcoming changes in the legislation. This is explained in
detail in the section Future of WEEE market- Policy and Legislation changes.

This can also be defined as a transformation for the business and working in a
pro-active manner, this threat can be decided as a biggest advantage for

SWOT Analysis (ESS)

1. Continuous



financial growth
2. Greater support with the policy
and environmental regulation

1. Failure to establish a PCS scheme

2. Lack of market penetration
3. Lack of frequent assessment of



3. Great


principles of

and operative

4. Continuous analysis of business

micro and macro

and financial sectors with new

components of business

strategies of assessment



1. An over look into the strategic

development plans for the future
2. Design the new business plans
with clear mention about efficient
3. Daily investigation of business
development (Analysis)
4. Developing





benchmarking them with the time

and other competitors
5. Delivering




indicators on a regular basis for

the evaluation
6. Work as pro-active group to build
and develop new business plans
with regard to changing policies
and legislation
7. Be prepared for the boom of the
market underlined by clear cut
planning. Unplanned operations
in the future or relying on the




1. Competitors
2. Legislation and policy changes
3. Transitional market changes

development will end up in a

heavy blow

Future of WEEE developments and Policy implementation
a. Researching future WEEE market
b. Investigating the streamline of policy and legislation changes

a. Researching future WEEE market

The WEEE Regulations came into force for the most part on 2 January 2007; however,
the deadline for ensuring the full take back, treatment and recycling of WEEE in the UK
is set for 1 July 2007. This article critically analyses the WEEE Regulations, explaining
the complexities involved and offers practical suggestions as to the steps businesses
should be taking in working towards compliance.

The section covers:

Demonstrating the responsibilities of ``producers''; distributors, business users

and local authorities;

The future prospects of WEEE arise in UK driven by the WEEE Regulations, prices
for non-compliance; and analysis of the implications for businesses of the WEEE
Regulations, including:
1. the increased costs;
2. the effect on SME's;
3. practical problems;
4. interactions with other legislation;
5. future actions
6. Future Market of WEEE an possible legislation changes

As discussed before, WEEE put on the market has been rapidly increasing rapidly since
2005. Despite the policy and legislative changes to drive the sustainable reduction of
WEEE wastes, the generation of the waste percentage has not even been pushing down
to even slight amount. It is estimated that in the UK alone approximately 1.8 million
tonnes of waste EEE (``WEEE'') is thrown away by householders and companies
The waste management strategy of UK during the years of 2004, 2007 and 2011 has
continuously reflected the importance of WEEE reduction which is accumulated in the
market. The waste management strategy as indicated in the following figure stresses
on the necessity of driving pressure-improved model of educating and creating
awareness in the people to drive the WEEE generation down has been of greater
importance to drive the WEEE to drive away from being landfilled or incinerated
without pre-treatment.

The presence of hazardous substances leaching from landfills due to un-processed

WEEE being landfilled contaminate soil and ground- water and the consequent
adverse impacts on the environment. This has resulted in identifying WEEE as the prior
choice when waste management is considered.
The implementation of the WEEE Directive in the UK has been a long and drawn out
process. It was due to be transposed into Member States legislation by 13 August 2004
and to come into force by 13 August 2005. After nearly four years of consultations, the
WEEE Directive has finally been implemented into UK law by the Waste Electrical and
Electronic Equipment Regulations 2006 (``the WEEE Regulations''). The WEEE
Regulations were made on 11 December 2006 and came into force, for the most part
on 2 January 2007
Statistical figure of WEEE
Of the UKs total of 300 million tonnes of waste a year, approximately 940,000 tonnes
is WEEE from domestic sources. This type of waste is growing three times faster than
any other municipal waste stream.
The new initiatives to drive further down the percentage of WEEE to be landfilled has
been the recent advancements registered nowadays. The debate about cutting down
the percentage of WEEE allowance for landfilling was initially made by the European
Commission (the EUs permanent executive body) in 2008. Amendments proposed by
the European Parliaments Environment Committee were debated and agreed by the

full European Parliament early in 2011. Then, in March of 2011 the European Council
of Ministers examined both the Commission and Parliament proposals and suggested
their own amendments.
The Parliament and Council are still discussing about the EU co-decisions to
determine the latest figures. This discussion is believed to be formally ending by Q3
of 2011. However, it appears that broad agreement on some of the general topic areas
has already been achieved for example it appears that WEEE collection and recycling
targets may well be changed although the final format and levels are still uncertain.
Looking at the Commission proposals, and suggested amendments, it is possible to
analyse how they could potentially be implemented in the UK - and therefore begin to
anticipate what effects they might have on UK WEEE producers, retailers and the UK
WEEE compliance market as a whole. The target setting suggestions are as follows:

Joining B2B Business sector to EEE

The European Council for WEEE in the new Article 7 discusses further about the WEEE
collection rate targets of 45% (to be achieved 4 years after the entry into force of the
recast) and 65% (to be achieved 8 years after the entry into force of the recast),
generates a huge prospect for AATFs as the WEEE collection rates are believed to
highly dependent on individual AATFs effort make the situation as the ground of
growth. Furthermore, the targets are expressed in terms of electrical and electronic
goods placed on the market; and do not distinguish between goods intended to be
used by private households and those intended to be used by those other than private

households. Therefore it is assumed that the proposed targets are intended to be

calculated from the sales of all EEE whether this is currently classed as business to
consumer (B2C) or business to business (B2B) equipment.
Use of Three Year Sales Averages
As noted above, different types of electronic goods are generally expected to spend
different amounts of time in use before being discarded as waste. In order to take
account of this the EU Council of Ministers has proposed that WEEE collection targets
should be based on the average quantities of EEE sold by producers in the previous
three years. Although this will have effects on individual producers, it does not have a
significant impact on the analysis of data or the conclusions reached in our analysis. In
an effort to reduce complexity we have therefore ignored these effects in the
presentation of results.
Treatment and Recovery Obligations
Although not explicitly mentioned, it is assumed that the current requirements for
producers to finance the appropriate treatment and recovery of all separately
collected WEEE will remain unchanged. This requirement does not affect our
conclusions, however, where the term collection has been used in the text in reference
to the obligations of EEE producers; it should generally be interpreted to mean
collection, treatment and recovery.
Obligation to Join a Compliance Scheme
Within the current UK WEEE compliance system all producers are forced to join
producer compliance schemes (PCS) to meet their WEEE collection, treatment and
recovery obligations. For simplicity we have assumed that this obligation will remain,
however, again this does not affect our conclusions.

The following are the main developmental scenarios in the prediction of future WEEE
generation in UK and policy changes which are highly likely to take place with regard
to WEEE collection targets, treatment targets and landfill allowances targets
UK WEEE Collection Rates
Graph (1) below shows total UK business to consumer (B2C) EEE sales along with the
total quantities of B2C WEEE reported to have been separately collected under the
WEEE Regulations.
Graph (1): UK B2C EEE sales and WEEE collection rates

Graph (1) shows a gradual increase in the weight of separately collected WEEE along
with a gradual reduction in the total weight of EEE put onto the market, both of which
have contributed to the calculated increases in the UK WEEE collection rate (expressed
as a percentage of EEE sales with calculated annual average figures shown at the top
of the chart for each year from 2007 to 2010).
Graph (2) below shows equivalent results for business to business (B2B) EEE sales and
WEEE collected:
Graph (2): UK B2B EEE sales and WEEE collection rates

The reported rates of EEE sales and WEEE collections for B2B equipment (shown in
graph (2)) are considerably lower than the equivalent B2C figures (shown in graph (1)).
However, since we have assumed that any proposed WEEE collection targets will be
set as a proportion of combined B2C and B2B EEE sales (see Methodology point 4)
graph (3) below shows combined EEE sales and WEEE collection rates:
Graph (3): Combined UK B2C and B2B EEE sales and WEEE collection rates

Looking more closely at the published figures,

Table (1): Combined B2C and B2B WEEE collected against EEE put onto the

On the assumption that the new initiatives will enter into force around late in 2011 and
the targets suggested by the European Council of Ministers are accepted. Graph (4)
shows the increases in WEEE collection rate which would need to be achieved in order
for the UK to meet these requirements (assuming no increases in EEE sales from the
2010 reported levels):

The green point is the UKs 2010 WEEE collection rate of 31%.

The red points are the possible 45% and 65% targets implemented 4 and 8 years
after 2011.

The blue point is the current WEEE collection target of 4kg per head of UK
population converted to an equivalent percentage of sales (based on a UK
population of 63M).

The black line shows the increase in UK B2C and B2B WEEE collection rate from
2007 to 2010.

The red line shows an indication of the WEEE collection rates that might need
to be achieved in interim years between 2010 and 2019 to provide a steady

increase towards the possible 45% and 65% targets from the current UK
reported WEEE collection rate.

The dotted line shows an indication of the WEEE collection rates that might
need to be achieved in interim years between 2010 and 2015 to provide a
steady increase towards the possible 45% target from the current 4kg per head
of population target.

Graph (4): UK WEEE collection rates and potential rates required to meet
increased targets.

For the UK to meet an overall WEEE collection target based on total EEE sales we have
assumed that the UK Government would implement targets, applicable to individual
EEE producers, which would similarly be based on the quantities of EEE that they place
on the market. We have postulated four different potential target setting scenarios
which could be applied through changes to the UK WEEE Regulations in order to meet
an overall UK collection target. For simplicity we have only listed the potential
consequences of applying targets up to the 45% level, however, similar conclusions
can be drawn for higher or lower target regimes.

WEEE Collection Rates

The high percentages of reported WEEE collection in category 11 (display screens) is
due partly to the fact that modern display screens are relatively light flat screen items,
whereas the majority of display screens collected for recycling are heavier CRTs
(cathode ray tubes). It is possible that technological advances may produce similar
outcomes for other EEE categories; however, we are not able to foresee and account
for such potential changes. Similarly, with regard to increases in sales, we cannot
predict how the UK EEE market will develop and hence cannot estimate how this will
affect required WEEE collection tonnages should a sales based WEEE collection target
be imposed.
For information, graph (5) shows the combined reported WEEE collection rates in the
UK from 2007 to 2010 and Graph (6) shows the WEEE collection rates that might be
required in intervening years in order for the UK to make a steady increase up to a
45% EEE sales based WEEE collection target under two arbitrary EEE sales scenarios.
Graph (5): UK quarterly reported WEEE collection rates

Graph (6): Annual WEEE collection rates required to meet a 45% EEE sales
collection target by 2015

If the reported 2010 sales figures for B2B and B2C EEE remained unchanged, the UK
would need to collect an extra 202k tonnes of WEEE to meet a combined 45% sales
based target by 2015.
If the B2C collection rate remained static at 38% this would require an increase in the
B2B collection rate from the calculated 2010 rate of 5% to 71%.
If the B2B collection rate remained static at 5% this would require an increase in B2C
collection rate from the calculated 2010 rate of 38% to 55%.
There is no reason for us to suspect that the collection rates of either B2B or B2C WEEE
will remain static, however, the above points lead us to consider whether one of our
initial assumption is correct i.e. if individual WEEE collection targets are set separately
for B2B and B2C sales then a number of questions and conclusions arise. For example:
Should we expect both B2B and B2C producers to meet the same EEE sales based
WEEE collection target (whether this is set at 45% or any other level)?

If the answer to this question is yes then this will further complicate target setting
scenarios. If the answer is no then on what basis should we determine which WEEE
collection source to encourage?
Furthermore, if differential collection targets are set for B2B and B2C producers - but
an overall 45% UK target based on all EEE sales is required to be met - then this may
infer cross subsidy of compliance burdens between the two WEEE streams.

b. Investigating the streamline of policy and legislation changes

Current Council recast text appears to describe the setting of EEE sales based targets
using combined sales figures from both B2B and B2C sources. Analysis shows that
target setting scenarios therefore assumes that any sales based WEEE collection
targets will apply to both business to business (B2B) and business to consumer (B2C)
However, a brief examination of WEEE collection rates (section 6) raised a number of
potential issues. If sales based WEEE collection targets are applied separately to both
B2B and B2C producers, it may be the case that WEEE collection and recovery evidence
from business and consumer sources could be required to remain separate with no
crossover of compliance evidence allowed.
A further potential complication lies in the fact that the recast text retains the
requirement for B2B producers to continue to meet the obligations placed on them
within Article 9 of the original Directive.
The original Article 9 text states:
Article 9
Financing in respect of WEEE from users other than private households Member States
shall ensure that, by 13 August 2005, the financing of the costs for the collection,
treatment, recovery and environmentally sound disposal of WEEE from users other

than private households from products put on the market after 13 August 2005 is to
be provided for by producers.
For WEEE from products put on the market before 13 August 2005 (historical waste),
the financing of the costs of management shall be provided for by producers. Member
States may, as an alternative, provide that users other than private households also be
made, partly or totally, responsible for this financing. Producers and users other than
private households may, without prejudice to this
If the recast Directive requires B2B producers to be faced with an additional obligation
to meet a sales based collection target along with the responsibilities above, then it is
possible that potential conflicts may occur. For example:
It is not immediately clear how the existing responsibilities can be applied in tandem
with a sales based WEEE collection target for B2B producers.
It is also unclear whether Article 9 above prohibits B2C producers from financing B2B
WEEE collection treatment and recovery and meeting any potential sales based WEEE
collection targets from B2B sources.
There are potentially challenges in meeting an EEE sales based WEEE collection target.
However, it is not yet clear whether the most appropriate means to reach such a target
would be through the implementation of kerbside WEEE collection. Before such a
solution is implemented it may be appropriate to examine what potential increases
could be achieved by maximising existing collection routes. For example, an increase
in the availability of mixed WEEE collection points and improved publicity and
encouragement for both public and business end users may provide much of the
required material.

Analysing Needs and evaluating options
a. Organisation modelling
b. Business process analysis
c. Identify options

a. Organisation modelling
There are a number of general planning considerations which are relevant to all
proposals for waste management facilities. These are issues which it is necessary for
applicants and waste planning authorities to have regard to whilst preparing and
determining applications for waste management proposals.
Waste Management Principles
PPG 10 lists four fundamental waste management principles which should represent
the main cornerstones of waste management strategy and planning. These have been
established primarily through European legislation starting with the 1975 Framework
Directive on Waste (75/442/EEC). Implicit in the denition of these principles is the
need to promote the concept of sustainable development. These cornerstones are:
Best Practicable Environmental Option
Regional Self Sufciency
Proximity Principle
Waste Hierarchy

Best Practicable Environmental Option

Best Practicable Environmental Option (BPEO) is dened in PPG 10, adopting the
denition of the Royal Commissions Twelfth Report on Environmental Pollution, as:
Waste Strategy 2000 notes that the determination of the BPEO is not a simple process
and BPEO varies from product to product, from area to area and from time to time. It
is expected that assessment methodologies should be comprehensive, exible,
iterative, and transparent.
It is important that a planning application for a larger, strategic waste facility should
demonstrate that the proposed development is consistent with an agreed BPEO for
the waste stream(s) to be managed. The way in which this can be achieved will vary
depending on availability of existing local and regional information on BPEO and the
relevance of that BPEO work to the waste streams to be managed by the proposed
Regional Self Sufciency and the Proximity Principle
These considerations suggest that most waste should be treated and disposed of in
the region where it is generated and as near as possible to its place of production. PPG
10 states that each region should make provision for facilities that have capacity to
deal with at least ten years supply of waste. The Regional Planning Bodies and RTABs
should take an overview of the waste needs and options for their region.
There are certain contradictions that may need to be reconciled when considering
these issues, including certain economies of scale and transport issues. In some
situations it may be appropriate for centralised facilities to be developed which take in
wastes from outside the immediate area, for example, the use of rail as a means of
waste transfer is generally not economic over short distances. Similarly achieving
certain economies of scale can be critical to the nancial viability of certain thermal
and mechanical processing operations.

b. Business process analysis

Waste Hierarchy
This is a theoretical hierarchy of techniques/approaches to waste management rst set
out in the EC Framework Directive. Waste disposal in the form of landll is at the
bottom of the hierarchy and waste minimisation and recycling towards the top. Waste
Strategy 2000 sets out the Governments priorities and targets in this regard.
One difculty with some simplistic interpretations of the waste hierarchy is that the
impression given is that options at the top of the hierarchy are good and options at
the bottom are bad. The reality is much more complicated. In any integrated waste
management strategy there needs to be a mix of facilities which must include provision
for disposal of residual waste as well as the provision of other options further up the
Environmental Impact Assessment (EIA)
The need to undertake an EIA in connection with proposals for waste management
facilities is based on the requirements of the EC EIA Directives (85/337/EEC and
97/11/EC). These were translated into English law by the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999. Specic
guidance on the application of the EIA Regulations is contained in DETR Circular 02/99.
Further guidance on EIA procedures is also contained in the DETR Blue Book
(Environmental Impact Assessment A Guide to Procedures, November 2000).
The key objective of the EIA procedures is to ensure that appropriate consideration is
given to those projects which have the potential to have a signicant effect on the
environment. It is not intended that EIA be used for development projects which are
likely to have only limited environmental impacts. The Regulations dene EIA projects
in two separate schedules. Schedule 1 identies projects which will always require EIA,

Schedule 2 identies projects that may require EIA subject to EIA screening and
consideration of factors such as its size, nature or location

c. Identify options
An important consideration for developers and waste planning authorities with regard
to planning proposals for waste facilities is the issue of need. Applicants are not usually
required to demonstrate the need for their proposed development or discuss the
merits of alternative sites, except where an Environmental Statement is required,
although need may be a consideration where material planning objections are not
outweighed by other planning benets. Such a requirement also applies generally to
minerals proposals. Normally the need statement for waste management facilities will
have regard to the following issues:
Existing waste ows and volumes;
Identication of the waste catchment area affected and sources of waste;
Existing provision of facilities dealing with the specic waste streams in question;
Assumptions on waste movements and patterns;
Assumptions on waste growth over appropriate time periods; and
Predictions on the identied shortfall in capacity over appropriate time periods.
Consideration of alternative sites and technologies is now recognised as an important
part of any proposal seeking planning permission for waste facilities. Where the
proposals are dened as an EIA project under the terms of the EIA Regulations,
consideration of alternatives is an obligatory requirement as dened under Schedule

4 Information to be included in an Environmental Statement. This state under Section

At present there is no clear guidance on the form or content of an alternatives
assessment. This is likely to vary according to the local context. For example it is
considered that where there is clear policy guidance in the relevant UDP or Waste Local
Plan (now local development documents) which indicates preferred sites, it is likely
that the scope of any alternatives assessment can be limited. Similarly if the relevant
Waste Strategy or BPEO assessment indicates certain preferences in terms of
technology or facility types then any assessment of alternative management options
in the planning application would be expected to draw upon this.
Where no such context is available to guide the choice of the preferred option, the
applicant may be expected to demonstrate that they have undertaken a methodical
appraisal of all the relevant alternatives. In terms of alternative sites this can involve a
constraints based assessment. Geographic information systems (GIS) and data sets can
be used as a tool to aid site selection