As you all know, the responsibility for the collection and recycling of luminaires and lamps has been completely transferred from LightRec to OPEN as of last year. As a result, this is the first annual report in which we, as ‘LightRec 2.0’, account for our activities as an industry advocate for producers and importers of energy-efficient lighting.
Our partners can continue to count on our committed advocacy, also under the OPEN umbrella. Above all by ensuring that the financial reserves built over the past two decades are deployed efficiently and for their originally intended purpose: collecting the accumulated backlog of used fluorescent tubes and energy-saving lamps, for at least the next ten years. That, after all, was the reason for our foundation years ago, and we will not shy away from that responsibility.
We try to secure the efficient use of resources in various ways. By initiating marketing and communication projects (campaigns) to stimulate ongoing collection efforts. By getting involved in policy debates, up to the European level, that concern the interests of our supporters. And by collaborating with other stakeholders wherever that may be useful.
With the latter in mind, LightRec is active in the representative organization Fedet-NLA, where we discuss trends and developments and are able to exercise (political) influence over laws and regulations concerning the acceleration of LED lighting in the Netherlands. Because Fedet-NLA is member of the European umbrella organization Lighting Europe, this also gives us a seat at the table at the EU level. This ensures that we have first-hand information on newly developed legislation and other politically sensitive dossiers.
I am pleased to report that the collection of fluorescent and energy-saving lamps remains at a satisfactory level. The collection of luminaires is also developing positively, in part thanks to the Incentive Scheme for Luminaires and OPEN's successful Wecycle programme for businesses. In addition, these results were realized with the waste management fees that we were able to reduce in 2023.
I am pleased to report that the collection of fluorescent and energy-saving lamps remains at a satisfactory level. The collection of luminaires is also developing positively, in part thanks to the Incentive Scheme for Luminaires and OPEN's successful Wecycle programme for businesses. In addition, these results were realized with the waste management fees that we were able to reduce in 2023.
On behalf of the Board, including my fellow Board members Judith Keirsmaekers (SG Lighting), Thomas Leenders (Signify), Andreas Adam (Ledvance) en Rolf Ibsen (Megaman), I would like to express my full confidence in ‘LightRec 2.0’, which continues to fulfill its role as an industry advocate in the Netherlands as well as on the European stage.
As an organization, OPEN is fully in development and is also gradually shifting its emphasis. For example, investments in knowledge are rising, especially in the area of circularity. While this was historically viewed as the exclusive domain of producers, it is becoming increasingly clear that OPEN can make a positive contribution as well. For example, by initiating projects that seek to apply circularity theories into circular practices. Our partners will be able to benefit from these developments in the future.
LightRec is directly represented on the Board of OPEN. In this way, we ensure that this umbrella for producers' representative organizations remains attentive to our partners' specific interests. After all, lighting is and remains a 'special' category of e-waste, subject to different parameters than, say, kitchen appliances or audiovisual electronics. We are also pursuing joint research, such as on how to optimize the collection and recycling of public lighting in collaboration with manufacturers, municipalities and installers. New circular business models are also being explored.
The recent addition of (formerly) Stibat, responsible for the collection of batteries, proves once again that OPEN has become a platform for collaboration and synergy. This development will be important for LightRec in the coming years, because many luminaires also contain batteries (e.g. emergency lighting, consumer luminaires and bicycle lighting). We also expect this to have a positive impact on the collection rates.
LightRec is represented on the Board of EucoLight, the European partnership of foundations involved in the collection and recycling of WEEE lamps and lighting products. On behalf of its 20 members, EucoLight is involved in all developments related to the WEEE directive, including legislation and standards applicable to the collection and recycling of WEEE lighting.
At the time of writing this Annual Report, a possible re-design of the current WEEE Directive is under discussion in Brussels. LightRec is directly involved through the EucoLight partnership. This has resulted in a first position paper, in which a number of initial recommendations are made. These concern further harmonization within the subcategories for lighting; eliminating any ambiguities within (W)EEE definitions for lighting; extending producer responsibility (same rules for all actors and a level playing field); tackling free riders on online marketplaces; and increased consideration of the waste that is available for collection. In the position paper, EucoLight members also dispute the usefulness of the so-called eco-modulation of fees (as multiple tiers of small products and low tariffs are difficult to distinguish). Finally, they advocate for improved coordination of EU member state legislation (which, at the very least, should not be contradictory).
Furthermore, our commitment is to seek to maintain, for the time being, a separate product group for lighting (i.e. the current category 3), as this makes it easier to accurately and transparently monitor the collection of discarded fluorescent tubes and energy saving lamps in the coming years.
Public advisory bodies and the government are still not utilizing the savings potential of LED to a sufficient extent. This deficit is noticeable not only in the advice concerning the urgently needed energy transition, but also in the government's own real estate portfolio and everything that falls under public lighting.
Together with Fedet-NLA and several Dutch LED manufacturers, LightRec has chosen to take the lead to help companies, (local) governments and other organizations make the switch to LED. To this end, we have invested heavily in a new national campaign: ‘Met LED kan het’. Throughout this campaign, the call to ‘choose LED’ is emphatically accompanied by the appeal: ‘and hand in your old lighting for recycling’.
Moreover, LightRec takes the position that, in addition to stimulating the switch to LED, better enforcement is also required. For example, an Energy Label C for commercial buildings is already mandatory as of 1 January 2023. Meeting this obligation should be regarded as part of (supply) chain liability.
LightingEurope represents the European lighting industry. This interest group lobbies the European legislature for laws and regulations that do justice to the specific characteristics of lighting products and that enable manufacturers to innovate in the areas of sustainability and circularity.
In addition, LightingEurope manages the application process for exemptions under the EU RoHS Directive on behalf of the lighting industry and users of lighting products. The aim is to further reduce the use of environmentally harmful substances in lighting products and to support the market in switching to alternatives when they become available.
Through Fedet-NLA, LightRec contributes to LightingEurope's ambitions in the area of sustainability, in line with the EU vision set out in the European Green Deal and the Circular Economy Action Plan. This vision includes energy saving efforts and extending the lifespan of products, as well as the collection and recycling of discarded lighting.
LightRec overhauled its website in 2023. This new website is more suitable for our organization's new role and is set up to optimally facilitate the process of informing and consulting our partners (the members of the ‘old’ LightRec).
Municipal
Retail
Social
Companies
Metal recyclers
Final total
(*)
The number of drop-off points reflects the number of locations listed on the Wecycle map, i.e. public drop-off points for consumers and/or companies. These are general Wecycle drop-off points, not necessarily (only) for lamps and/or luminaires.
(**)
The number of service points is the total number of locations registered with the OPEN Foundation (in myOPEN), regardless of whether they are publicly accessible for consumer/collection companies.
The collection of discarded fluorescent and energy-saving lamps in 2023 is at a similar level as in 2022. The collection percentage of these lamps is now 217%. This is partly due to the continuous support that LightRec provides to OPEN regarding public campaigns. LightRec will continue these efforts until the last conventional lamps have been removed from the market. After all, they not only contain harmful substances such as mercury, but also useful raw materials that can be recovered. It is estimated that it will take about another ten years for the last fluorescent and energy-saving lamps to be removed and collected.
The collection of LED lamps, on the other hand, is unfortunately still growing only marginally. As a result, the total collection percentage for these lamps is now 2%. This does not meet the legal collection requirement of 65%. The main reason is that LED lamps were introduced to the market relatively recently. They also have a very long lifespan, just like solar panels, which is why the prescribed collection percentage of 65% is not realistic.
However, considering the commercial success of LED lighting, a higher collection percentage should now be plausible. LightRec therefore continues to urge OPEN to continue to pay sufficient attention to the collection and processing of LED lamps and to continue to monitor the progress of collection efforts closely. In turn, LightRec also continues to use its reserves for the transition from conventional lamps to LED lamps by sponsoring the Fedet-NLA campaign ‘Met LED kan het'.
The collection of luminaires saw a solid increase of more than 8% to 6814 tonnes. This is mainly due to additional efforts in the collection of professional luminaires in renovation and demolition projects. OPEN is very active in this area with the programme 'Wecycle for companies' and its Incentive Scheme.
There is still a considerable amount of catching up to do in the collection of luminaires from consumers. The total collection percentage of luminaires is now around 20%. This is partly due to a sharp increase in PoM in recent years as a result of the introduction of new LED products. Consumers must continue to be reminded that luminaires do not belong in the residual waste bin. But luminaires also still too often disappear into the scrap metal containers at recycling centres. Finally, similar to LED lighting, LED luminaires are still hardly ever discarded due to their recent introduction and long lifespan.
* up to 14-8-2018 excl. household luminaires, from 15-8-2018 incl. household luminaires.
Just like individual product foundations in the past, OPEN must also comply with the collection norm set by the EU. From 2019, the collection target is 65% of the average weight of EEE that has been placed on the market in the Netherlands in the previous three years (‘Put on Market’, or PoM).
As in 2022, the collection target of 65% was not achieved in 2023. While the percentage is increasing, that is primarily attributed to a decreased PoM (particularly of major appliances and solar panels). This effect is expected to be temporary, so in the coming years, OPEN will again have to make a considerable effort to reach the 65% norm. A new AVV must be granted in 2025, which will almost certainly be premised on the 65% norm again. Through our membership of OPEN's Supervisory Board, LightRec will keep a close eye on these efforts. In addition, the collection of both conventional lamps and LED lamps must at least be in line with the other countries in the European Union.
Meanwhile, LightRec together with OPEN are of the opinion that the 65% collection target is outdated. First of all, it does not respond to the need to transition to a circular society, as described in the European Green Deal and also in the Dutch national current coalition agreement. After all, the collection norm only concerns ‘collection for recycling’, and not ‘collection for refurbishing or repairing devices’. Furthermore, the target does not take into account the increasing electrification of society, in part due to the rise of working from home and the energy transition.
And perhaps even more essential: many of the devices brought onto the market today have a (much) longer lifespan than three years, and therefore do not count towards the three-year average on which the current scheme is based. In fact, the current 65% target encourages devices to be taken off the market after just three years in order to include them in the collection result. LightRec supports this view of OPEN, because LED lamps in particular have a lifespan of twenty years or more. Moreover, many luminaires can easily be given a second life via the circuit of thrift shops.
At the moment, our processing partner Indaver regularly conducts random samples to determine the share of LED lamps in the total volume of discarded lighting. For the time being, this fluctuates around 5% of the total. This small share can simply be ‘recycled along’ with the main flow (of fluorescent and energy-saving lamps). If the share of LED lamps increases to 15% or more in the future, this will no longer be possible and the LED flow will have to be processed separately. Efforts are already being made to develop AI systems for separating both flows, as they are often difficult to distinguish from each other with the naked eye.
For years, we have been reporting the actual costs incurred by LightRec in our financial report. However, due to the complete transfer of producer responsibility from LightRec to OPEN, effective 1 January 2023, LightRec's operational costs have sharply declined; these are now largely borne by OPEN.
Regarding the marketing budget, OPEN does allocate its own budget for the collection and processing of all electrical appliances, lamps and batteries, but LightRec deliberately continues to devote additional campaign funding (financed from its reserves) to research, information campaigns and inherent initiatives.
LightRec's collected volumes have formally dropped to zero, because this is now the responsibility and result of OPEN. For these reasons, we will simplify the cost overview in our reports from 2024 onwards.