Core messages for the transposition of the WEEE Recast Directive into national laws

Published: 18 April 2013

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Policies & Issues:

In view of the transposition of the Recast Waste Electrical and Electronic Equipment (WEEE) Directive by EU member states, Orgalime, which represents producers of electrical and electronic equipment across all categories, calls on national legislators to ensure that the recast and its transposition leads to improved environmental protection as well as greater efficiency and more effective enforcement of the Directive.  It is vital that the Recast and its transposition do not create additional administrative burden for producers to comply with, without any environmental benefit, given the goals of the Recast and that producers have made investments, both financial and human, for ensuring compliance with the Directive. 

Industry therefore calls for:

  • A proper transposition of the given scope exclusions at member states level.
  • An adequate transposition of articles 7.2 and 16.4 for member states to demonstrate achievement of the minimum Collection Rate. For this purpose:
  • Building up a proper member states data base on all WEEE received to pave the way for a Collection Rate based on 'WEEE generated' and thereby contribute effectively to the EU’s and Member States’ Resource Efficiency Policy objectives.
  • Consistently gathering and making available information on all WEEE exported.
  • Implementing the clear, common understanding on the way to target all flows of B2B and B2C waste other than those of official WEEE channels, and to appropriately gauge them at national level, notably through
    • An obligation to properly treat and report WEEE also to these actors to help fill existing data gaps and ensure proper treatment of WEEE collected through other routes than producer compliance schemes. 
    • Mandatory reporting obligations for all recyclers.
    • Enforcement with periodic audits of such other actors by Member States following their obligations under article 16.4.
  • Stopping illegal transboundary shipments, while allowing legitimate shipments by producers or third parties acting on their behalf, for repair, refurbishment, remanufacturing, reuse of professional products
  • To maintain that member states shall allow producers to voluntarily show the collection and recycling costs.
  • Taking into account that certain provisions of WEEE require a national approach (i.e.: articles 5, 7, 8, 11, 12, 13, 16) while others require a European approach (i.e.: articles 4, 14 and 15)
  • Support for establishing collection, treatment and recycling standards