1. Evidence Notes are no longer abundant
Household collection volumes in several categories have slipped below long-run averages. Where collected tonnage falls and producer obligations don't, the price of Evidence Notes — the tradeable units schemes use to demonstrate compliance — rises. Small movements in collection rate become large movements in price.
2. The Compliance Fee is doing more work
When schemes can't source enough Evidence Notes to meet obligations, the difference is settled via the Compliance Fee. The fee was originally designed as a backstop; in practice it's now a meaningful share of total system cost for several categories. Producers ultimately fund it through their scheme.
3. Category mix is shifting
The UK EEE market is steadily moving toward small mixed electronics, displays and batteries-integrated devices — all of which are relatively expensive to treat correctly. Producers whose product mix has shifted in the same direction see a double effect: more tonnage in higher-cost categories.
What to do about it
- Audit your placed-on-market data. Many producers carry legacy category mis-allocations that quietly cost money every year.
- Re-tender your PCS contract. Pricing structures vary widely; stable incumbents aren't always the cheapest.
- Look at product design. Eco-design contributes to lower lifetime compliance cost, not just better marketing copy.
- Engage with reform consultations. The producers shaping the next framework will be the ones with the lowest costs inside it.