Policy No: EPU/05/2024/V1
| Authority | Department of Environment, Food and Agriculture |
|---|---|
| Date received | 2024-12-16 |
| Outcome | Not upheld |
| Outcome date | 2025-04-07 |
| Case ID | 4323793 |
Summary
A request was made for all planning documents, meeting notes, and correspondence regarding the Waste Regulation Policy for Small Mixed Waste Electrical and Electronic Equipment (SMW). The response disclosed a 10-page guidance note detailing the identification, hazards, storage, and transport requirements for SMW, though the outcome of the FOI case was 'Not upheld'.
Key Facts
- The policy covers Small Mixed Waste Electrical and Electronic Equipment (SMW), excluding items like CRT TVs and refrigerators collected separately.
- SMW is classified as hazardous for shipment to England due to the difficulty of separating hazardous components.
- Exporting hazardous WEEE to England requires a Transfrontier Shipment Notification and payment of fees to the Environment Agency.
- The guidance note provides best practices for handling batteries and other hazardous components to prevent fire and pollution.
- The FOI case outcome was 'Not upheld' on 2025-04-07, despite the disclosure of the guidance document.
Data Disclosed
- Policy No: EPU/05/2024/V1
- Effective Date: 01/01/2025
- Date received: 2024-12-16
- Outcome date: 2025-04-07
- 134 pages
- 2 documents
- Page 1 of 10
- Page 2 of 10
- Page 3 of 10
- Page 4 of 10
Original Request
Please supply copies of all documents relating to the planning and implementation of the Waste Regulation Policy for Small Mixed Waste Electrical and Electronic Equipment (SMW). Include the papers that were submitted to the Minister / Members for approval and copies of any meeting notes relating to this matter. Also include all emails between officers and any third party as well as internal emails, notes and correspondence. Some references are listed below to enable you to gather this information. Waste Regulation Policy for Small Mixed Waste Electrical and Electronic Equipment (SMW) Policy No: EPU/05/2024/V1 Policy Approved: Yes Effective Date: 01/01/2025
Data Tables (39)
| Battery type | Crush Hazard | Explosi on Hazard | Fire Hazard | Self heating Hazard | Hydrog | Toxic Hazard | Leakag e Hazard | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| en | |||||||||||||||||||||||
| Product | |||||||||||||||||||||||
| ion | |||||||||||||||||||||||
| Carbon Zinc | X | X | X | X | X | X | |||||||||||||||||
| Zinc chloride | X | X | X | X | X | X | ✓ | ||||||||||||||||
| Alkaline | X | X | X | X | X | X | ✓ X | ||||||||||||||||
| Lithium button | X | X | X | X | |||||||||||||||||||
| Mercury | ✓ | ✓ X | ✓ X | X | X | X | |||||||||||||||||
| Silver oxide | ✓ | X | X | X | ✓ X | X | |||||||||||||||||
| Zinc air | ✓ X | ✓ X | X | X | X | X | |||||||||||||||||
| Lead acid | X | ✓ X |
| Crush |
|---|
| Hazard |
| Explosi |
|---|
| on |
| Hazard |
| Fire |
|---|
| Hazard |
| Self |
|---|
| heating |
| Hazard |
| Toxic |
|---|
| Hazard |
| Leakag |
|---|
| e |
| Hazard |
| Alkaline | X | X | X | X | X | X | X | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| rechargeable | |||||||||||||||||||||||
| Lithium ion | X | X | X | ||||||||||||||||||||
| Lithium polymer | ✓ | ✓ | ✓ | ✓ | X | X | |||||||||||||||||
| Nickel Cadmium | ✓ | ✓ X | ✓ X | ✓ X | X | ✓ | |||||||||||||||||
| Nickel met hydride | ✓ | X | X | X | ✓ X | ✓ X | |||||||||||||||||
| Fuel cells | ✓ X | X | ✓ | X |
| • Printed circuit boards |
|---|
| • Plastic casings, cables and other components |
| • Insulation foam |
| • Cooling agents |
| • Flame retardants |
| • Activated glass and screen phosphors |
| • Cathode ray tubes |
| • Capacitors |
| • Ni-Cd batteries |
| • Printed circuit boards |
|---|
| • Plastic casings, cables and other components |
| • Insulation foam |
| • Cooling agents |
| • Flame retardants |
| • Activated glass and screen phosphors |
| • Cathode ray tubes |
| • Capacitors |
| • Ni-Cd batteries |
| TABLE 1 | Eastern CA site | Southern CA site | Northern CA site | Western CA site | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Fridges | Small | Large | XL | Small | Large | XL | Small | Large | XL | Small | Large | XL |
| 2021/22 | 495 | 463 | 24 | 243 | 147 | 11 | 200 | 191 | 10 | 240 | 269 | 29 |
| 2022/23 | 480 | 320 | 14 | 209 | 143 | 8 | 198 | 161 | 9 | 267 | 189 | 22 |
| 2023/24 | 449 | 321 | 21 | 186 | 125 | 8 | 189 | 142 | 13 | 240 | 185 | 13 |
| TABLE 2 | ECA site | SCA site | NCA site | WCA site | ||||
|---|---|---|---|---|---|---|---|---|
| TVs | PCs | TVs | PCs | TVs | PCs | TVs | PCs | |
| 2021/22 | 1195 | 338 | 352 | 131 | 339 | 148 | 572 | 757 |
| 2022/23 | 1124 | 284 | 414 | 109 | 373 | 126 | 615 | 506 |
| 2023/24 | 1110 | 291 | 382 | 172 | 384 | 136 | 688 | 270 |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDAC |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| REDACTED | |
|---|---|
| REDACTED |
| GC020 |
|---|
| Electronic scrap (such as printed circuit boards, electronic components, wire) and reclaimed electronic components suitable for base and precious metal recovery. |
| 1HT | |
|---|---|
| Email: | askshipments@environment-agency.gov.uk |
| @gov.im>; | REDACTED | |
|---|---|---|
| REDACTED | ||
| REDACTED |
| REDACTED |
|---|
| REDACTED |
| 20 01 36 – discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35 | Bulbs - non fluorescent, Civic amenity waste, Bulbs - Non Fluorescent, Light bulbs (non fluorescent) |
| 16 02 14 - discarded equipment other than those mentioned in 16 02 09 to 16 02 13 | Bulbs - non fluorescent, Capacitors (without PCBs or PCTs), Bulbs - Non Fluorescent, Computer keyboards, Computers, Appliances - domestic, Appliances - domestic, Cookers, Agricultural machinery, Cookers - microwave, Domestic appliances (electrical), Elect |
| EWC | Description | ||||
| 16 02 09* | transformers and capacitors containing PCBs | ||||
| 16 02 10* | discarded equipment containing or contaminated by PCBs other than those | ||||
| mentioned in 16 02 09 | |||||
| 16 02 11* | discarded equipment containing chlorofluorocarbons, HCFC, HFC | ||||
| 16 02 12* | discarded equipment containing free asbestos | ||||
| 16 02 13* | discarded equipment containing hazardous components (#) other than those | ||||
| mentioned in 16 02 09 to 16 02 12 | |||||
| 16 02 14 | discarded equipment other than those mentioned in 16 02 09 to 16 02 13 | ||||
| 16 02 15* | hazardous components removed from discarded equipment | ||||
| 16 02 16 | components removed from discarded equipment other than those mentioned | ||||
| in 16 02 15 | |||||
| 20 01 35* | discarded electrical and electronic equipment other than those mentioned in | ||||
| 20 01 21 and 20 01 23 containing hazardous components (#) | |||||
| 20 01 36 | discarded electrical and electronic equipment other than those mentioned in | ||||
| 20 01 21, 20 01 23 and 20 01 35 | |||||
| Permitted activities | |
|---|---|
| Description of activities | Limits of activities |
| R13: Storage of wastes pending any of the operations numbered R1 to R12 (excluding temporary storage, pending collection, on the site where it is produced) R3: Recycling/reclamation of organic substances which are not used as solvents R4: Recycling/reclamation of metals and metal compounds | Treatment consisting only of sorting, dismantling, separation, shredding, screening, grading, baling, shearing, compacting, crushing, granulation, repair or refurbishment, or cutting of waste into different components for recovery. There shall be no treatment of WEEE containing ozone depleting substances. There shall be no treatment of batteries except for sorting. |
| Version No. | Date Issued | Description |
|---|---|---|
| 1 | 21.12.2023 | DRAFT V1 |
| Date | Rev No. | Description | ||||||
|---|---|---|---|---|---|---|---|---|
| TBC | DRAFT | Initial document | ||||||
| Battery type | Crush | Explosion | Fire | Self heating | Hydrogen | Toxic | Leakage | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Hazard | Hazard | Hazard | Hazard | Production | Hazard | Hazard | |||||||||||||||||
| Carbon Zinc | X | X | X | X | X | X | ✓ | ||||||||||||||||
| Zinc chloride | X | X | X | X | X | X | ✓ | ||||||||||||||||
| Alkaline | X | X | X | X | X | X | X | ||||||||||||||||
| Lithium button | ✓ | ✓ | ✓ | X | X | X | X | ||||||||||||||||
| Mercury | ✓ | X | X | X | X | ✓ | X | ||||||||||||||||
| Silver oxide | ✓ | ✓ | X | X | X | X | X | ||||||||||||||||
| Zinc air | X | X | X | ✓ | X | X | X | ||||||||||||||||
| Lead acid | ✓ | ✓ | X | X | ✓ | ✓ | ✓ | ||||||||||||||||
| Alkaline rechargeable | X | X | X | X | X | X | X | ||||||||||||||||
| Lithium ion | ✓ | ✓ | ✓ | ✓ | X | X | X | ||||||||||||||||
| Lithium polymer | ✓ | ✓ | ✓ | ✓ | X | X | ✓ | ||||||||||||||||
| Nickel Cadmium | ✓ | X | X | X | X | ✓ | ✓ | ||||||||||||||||
| Nickel met hydride | ✓ | X | X | X | ✓ | X | X | ||||||||||||||||
| Fuel cells | X | ✓ | ✓ | X | ✓ | X | ✓ |
| • Printed circuit boards |
|---|
| • Plastic casings, cables and other components |
| • Insulation foam |
| • Cooling agents |
| • Flame retardants |
| • Activated glass and screen phosphors |
| • Cathode ray tubes |
| • Capacitors |
| • Ni-Cd batteries |
| • Printed circuit boards |
|---|
| • Plastic casings, cables and other components |
| • Insulation foam |
| • Cooling agents |
| • Flame retardants |
| • Activated glass and screen phosphors |
| • Cathode ray tubes |
| • Capacitors |
| • Ni-Cd batteries |
| REDACTED |
|---|
| REDACTED |
| 20 01 36 – discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35 | Bulbs - non fluorescent, Civic amenity waste, Bulbs - Non Fluorescent, Light bulbs (non fluorescent) |
| 16 02 14 - discarded equipment other than those mentioned in 16 02 09 to 16 02 13 | Bulbs - non fluorescent, Capacitors (without PCBs or PCTs), Bulbs - Non Fluorescent, Computer keyboards, Computers, Appliances - domestic, Appliances - domestic, Cookers, Agricultural machinery, Cookers - microwave, Domestic appliances (electrical), Elect |
Full Response Text
Page 1 of 10
Department of Environment, Food and Agriculture
Rheynn Chymmltaght, Bee as Eirinys
Guidance Note for the Identification and Handling of Small Waste Electrical & Electronic Equipment Contents 1.0 Purpose of the Guidance: ........................................................................................................................................... 2 2.0 General background .................................................................................................................................................... 2 3.0 Types of Small Mixed Waste Electrical and Electronic Equipment ............................................................................. 2 4.0 European Waste Catalogue (EWC) Codes ................................................................................................................... 5 5.0 Storage and Handling .................................................................................................................................................. 5 6.0 Equipment containing batteries ................................................................................................................................. 6 6.1 Types of batteries ................................................................................................................................................ 6 6.2 Hazards associated with batteries ..................................................................................................................... 6 7.0 Equipment containing other hazardous components ................................................................................................ 7 8.0 Transport of Small Mixed Waste Electrical and Electronic Equipment ...................................................................... 8 Annex A – Equipment and components that contain hazardous substances ................................................................ 10
Page 2 of 10
1.0 Purpose of the Guidance:
The purpose of this document is to provide background information on the nature and potential hazards of
receiving and storing and handling Small Mixed Waste Electrical and Electronic Equipment (SMW). Best
practice recommendations are also included for personal supervising the reception of the SMW and
for those operatives handling and storing and monitoring the SMW prior to loading for export.
2.0 General background
Small Mixed Waste Electrical and Electronic Equipment (SMW) includes a wide range of waste electrical and
electronic items including: small household appliances, IT and communications equipment, powered tools,
toys and sports equipment, medical devices, control instruments, smoke detectors and dispensers.
This means effectively that this group includes any WEEE that is not already separately collected in their own right – i.e. CRT TVs and flat screen monitors, refrigeration equipment, large household appliances and fluorescent lamps and tubes.
Due to the wide range in composition of this waste stream, there is a high potential for hazardous WEEE to be included, or WEEE that contains internal hazardous components.
Where there is uncertainty or the SMW has not been sorted at the reception point, the entire consignment of SMW must be classed as hazardous for the purposes of shipment to England for treatment and coded using both the relevant hazardous and non-hazardous EWC codes.
In the UK at household waste recycling centres (HWRCs) SMW is classified as hazardous due to the difficulty of separating non-hazardous from hazardous SMW.
For shipment to England for recycling, a Transfrontier Shipment Notification is required to authorise export of hazardous WEEE which will require payment of appropriate fees to the Environment Agency, pre- notification of shipments and financial guarantee. There is however no requirement for a dangerous goods note or for the transport to have ADR drivers.
The reception and storage process of the SMW should be managed carefully to prevent uncontrolled emissions, risk of fire and risk to health or the dispersion of pollutants into residual waste streams. 3.0 Types of Small Mixed Waste Electrical and Electronic Equipment
Page 3 of 10
There are many types of SMW which can be identified by the WEEE symbol indicating that the product should
not be discarded as unsorted waste but must be sent to separate collection facilities for recovery and
recycling. The WEEE marking appears on any electrical and electronic equipment placed on the EU market.
Page 4 of 10
WEEE Symbol
The WEEE on the EU market should have a Lithium ion battery symbol.
Lithium Ion Battery Symbol
Li-ion
Li
SMW categories
• Carpet sweepers & carpet cleaners • Sewing machines and Knitting machines • Irons & clothes pressers • Toasters • Fryers • Grinders, & coffee machines • Electric knives • Hair-cutter, hair dryer, tooth brushers, & shavers • Clocks, & watches • Scales Small household appliances • Personal computers (CPU, mouse, screen and keyboard included) • Laptop computers (CPU, mouse, screen and keyboard included) • Printers • Electrical and electronic typewriters • Pocket and desk calculators • Telephones - Cordless telephones & Mobiles) • Answering systems IT & Communication equpment • Radios • Video cameras & recorder • Video recorders • Audio amplifiers • Musical instruments Consumer equipment • Drills • Saws • Sanders • Tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses • Tools for mowing or other gardening activities Electrical & Electronic tools • e-cigerettes • Electric toys with or without batteries • Hand-held video game consoles • Video games • Computers for biking, diving, running, rowing, etc. • Sports equipment with electric or electronic components Toys, leisure and sports equipment • Smoke detectors • Heating regulators • Thermostats Monitoring & control equipment
Page 5 of 10
4.0 European Waste Catalogue (EWC) Codes
The EWC codes for SMW include:
20 01 35 / 16 02 13 discarded electrical and electronic equipment containing hazardous components
(other than those mentioned in 20 01 21 and 20 01 23 or 16 02 09 to 16 02 12)
20 01 36 / 16 02 14 discarded electrical and electronic equipment (other than those mentioned in 20 01
21, 20 01 23 and 20 01 35 or 16 02 09 to 16 02 13)
5.0 Storage and Handling
Small Mixed Waste Electrical and Electronic Equipment (SMW) should not be placed in the battery recycling
bin, metal skip or EfW (burnable) skips at Civic Amenity Sites or in household waste bin at home.
A detailed risk assessment should be initiated, implemented and reviewed on a regular basis to consider all aspects of receiving and storing SMW and separated batteries at the premises, and any risks to personnel and visitors (including those who may be less-abled, old or young).
Supervisory measures are recommended at the reception points at Waste Facilities e.g. Civic Amenity Sites
and Transfer Stations to ensure appropriate separation of SMW. Advice shall be given to the public and
commercial companies of the need to remove accessible batteries and cooking fats and other non-WEEE
waste (e.g. cardboard, general rubbish, petrol operated equipment) where possible prior to arriving at the
Waste Facility, or to present the equipment at a pre-inspection area so that reception point personnel can
assess it before placing into the correct collection container / area.
Care should be taken that SMW (that may contain batteries and other hazardous components) is not damaged, crushed or pierced during reception and handling and storage and re-loading on to the container being dispatched to the downstream treatment facility.
Accessible batteries should be removed from SMW when arriving at the reception point. Action should be immediately taken for any battery that has been damaged, dented or pierced. These should be segregated from other batteries and stored in receptacles suitable for waste batteries, e.g. made of a non-combustible, non-metallic (i.e. non-conductive) material with a high melting point.
Ideally, the WEEE should be stored under a weather-proof cover – e.g. inside a dedicated building, under a large canopy, large canvas sheet or in a wheelie bin etc. This is because water (.g. rain) can cause short- circuits in loose batteries resulting in fires / explosions.
A suitable number of dry powder fire extinguishers should be available and immediately accessible in the case of a fire and in accordance with the fire plan. Suitable rated fire extinguishers should be considered for metal based / lithium storage areas.
A monitoring programme of the storage areas should be in place, looking out for signs of smoke / excessive heat (e.g. plastic casings becoming distorted etc.). Outside of operational hours consideration should be given to installing heat and/or smoke detectors.
Sealed batteries should not be removed from the WEEE unless it is safe to do so with the correct tools, equipment, risk assessment, and procedures in place and should only be removed by trained staff. ☞
Page 6 of 10
6.0 Equipment containing batteries 6.1 Types of batteries There are three types of batteries –
•
Primary battery (i.e. AA, AAA, C, D and PP3):
A cell or battery that is not intended to be recharged and is discarded after use.
•
Secondary battery (i.e. nickel metal hydride, rechargeable alkaline, nickel cadmium):
A cell or battery which may be recharged after discharge.
•
Rechargeable battery (i.e. lithium ion and lithium polymer):
One or more secondary cells that may be repeatedly discharged and restored to full electrical capacity
by the application of an electric current.
Secondary / rechargeable batteries are to found in electronic cigarettes, mobile phones, laptops and tablet computers, satellite navigation equipment, radios, torches, cameras and portable tools / vacuum cleaners etc. and many other appliances.
Numerous incidents worldwide have been associated with batteries causing smoke, fire, extreme heat or explosions at recycling centres and treatment facilities as well as on collection vehicles and on passenger and cargo planes and passenger and commercial ferries (a significant number of which have been associated with lithium batteries).
Lithium batteries are particularly hazardous if not stored correctly. Not only do lithium batteries burn fiercely with a very large heat output, there is the additional hazard that lithium cannot be extinguished using water or water based extinguishers. Most fires have been the result of inappropriate packaging or handling, which caused damage or electrical short circuits. For more information on Lithium Ion Batteries Storage and Handling see EPU guidance: • Battery Collection Guidance
6.2 Hazards associated with batteries Summary of the hazards associated with some common types of batteries
Battery type
Crush
Hazard
Explosi
on
Hazard
Fire
Hazard
Self
heating
Hazard
Hydrog
en
Product
ion
Toxic
Hazard
Leakag
e
Hazard
Carbon Zinc
X
X
X
X
X
X
✓
Zinc chloride
X
X
X
X
X
X
✓
Alkaline
X
X
X
X
X
X
X
Lithium button
✓
✓
✓
X
X
X
X
Mercury
✓
X
X
X
X
✓
X
Silver oxide
✓
✓
X
X
X
X
X
Zinc air
X
X
X
✓
X
X
X
Lead acid
✓
✓
X
X
✓
✓
✓
See Annex A for more detailed storage and handling controls
☞
Page 7 of 10
Alkaline
rechargeable
X
X
X
X
X
X
X
Lithium ion
✓
✓
✓
✓
X
X
X
Lithium polymer
✓
✓
✓
✓
X
X
✓
Nickel Cadmium
✓
X
X
X
X
✓
✓
Nickel met hydride ✓
X
X
X
✓
X
X
Fuel cells
X
✓
✓
X
✓
X
✓
7.0 Equipment containing other hazardous components
The UK has created a technical guidance for the classification and assessment of Waste – Waste Classification
Technical Guidance WM3:
https://www.gov.uk/government/publications/waste-classification-technical-guidance
Often WEEE is found to contain components with hazardous substances or POPs, for example: • Printed circuit boards • Plastic casings, cables and other components • Insulation foam • Cooling agents • Flame retardants • Activated glass and screen phosphors • Cathode ray tubes • Capacitors • Ni-Cd batteries
For Small Mixed WEEE items it is difficult to satisfy that the WEEE is non-hazardous, therefore it should be treated and transported as hazardous WEEE unless it is possible to demonstrated, with supporting evidence, how this has been determined as non-hazardous.
Pre-2008 is highly likely to have plastic parts that contain hazardous Persistent Organic Pollutants (POPs).
Historical WEEE (pre-1996) is highly likely to contain more hazardous components or substances, with the very old items (e.g. pre-war) being more risky as the use of lead, asbestos, mercury and radio-active materials in the manufacture of new equipment was more common at that time. These WEEE items may not have the WEEE symbol. The absence of the crossed out wheelie bin symbol also means the equipment is post August 2005 (when the symbol became mandatory on new equipment).
SMW containing hazardous components includes:
Mercury containing components Switches, thermometers, backlights and batteries etc. Mercury switches are most likely to be present in older items manufactured before 1985 e.g. irons, coffee machines, telephones and monitoring and medical equipment. Any SMW flat screen devices (iPads; tablet PCs; laptops etc.) will also potentially contain mercury backlights. Facial tanners and other types of ‘sun-bed’ will contain gas discharge lamps (with mercury content).
Items containing radioactive sources Generally marked with a yellow ionising radiation trefoil symbol (i.e. on some smoke detectors). Other WEEE items which could contain radioactive components include some older clocks and watches (e.g. those with fluorescent dials), new Kenwood “safety toasters” and other specialist medical equipment.
Page 8 of 10
Equipment containing asbestos components
Include old coffee pots, irons, toasters and hairdryers.
Ceramic fibres
Are found in some solid cooker hobs, heating elements and storage heaters (especially in equipment
manufactured prior to 1998). Damage to these can cause small fibres to be dispersed into the air and could
cause skin irritation and breathing difficulties.
Small refrigeration equipment Dehumidifiers, air conditioning equipment should not be collected with SMW but segregated with the other refrigeration equipment. These will contain gases (sometimes ODS) and possibly oil.
Liquids Oil-filled radiators, cooking equipment (e.g. deep fat fryers), larva lamps, mercury components (see above) and large tools and
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