Orgalime reaction to kick-off meeting of the Technical Working Group on "Best Environmental Management Practices in the Electrical and Electronic Equipment Manufacturing Sector”

Following the kick-off meeting on the Sectorial Reference Document (SRD) on Best Environmental Management Practices (BEMPs) for the Electrical and Electronic Equipment (EEE) Manufacturing sector of 23-24 February 2015, Orgalime would like to provide the following comments on the draft report tabled by the Commission´s contractor, the Öko-Institut, at this occasion. 

 

We appreciate the possibility to provide feedback on the draft report at this stage, while we would have considered a more thorough information exchange with the sector from the outset of the process beneficial for the consistency of its outcome and further acceptance within the sector. 

 

Overall, the scope, focus and overall purpose of the draft report and proposed 21 BEMPs continue to create confusion in the EEE sector. In the absence of a clear methodology and questionable data, as well as unclear linkages to other relevant legislation applying to the sector, it remains unclear to us in how far the future BEMPs would fulfil their objective of helping organisations to better focus on the most important environmental aspects in the sector.

Indeed, the use of EMAS in the sector remains somewhat limited today due to its high level of bureaucracy and insufficient flexibility to follow technological developments in time. 

 

We therefore consider the listed BEMPs as company specific examples rather than representative references or valid future standards for the entire EEE sector. Given this, we welcome and support the Commission´s statement at the kick off meeting that the EMAS.