Scope is the Anchor for any Legislation – Do not Waste the Chance for a Better WEEE Directive

Published: 12 January 2011

Policies & Issues: Environment

Orgalime’s fundamental request to regulators is to ensure an EU legislation that is workable and enforceable in practice by supporting the following main proposals:

• Stick with a clearly defined scope of ten categories of WEEE covered by the Directive – the consequences of the proposal for an open scope have not been subject of an impact assessment. We would like to remind regulators that the basic aim of the directive is to deal with the growing household waste stream.

• Introduce a distinct but comprehensive set of scope exclusions, including: military equipment; equipment which is part of another type of equipment not within the scope of WEEE; fixed installations; large scale industrial tools; non road mobile machinery; any means of transport; photovoltaic modules; fixed parts of a building; filament light bulbs and implanted and infected medical devices.

• Reject any illustrative list of product examples covered by the Directive, since such a list can never be complete or follow technological developments in a timely manner.

• As this Directive is under Article 192 of the Treaty on the Functioning of the EU, it is all the more important that the scope should be clearly defined within boundaries so as to not radically increase the uncertainty which is already, today, faced by producers under the existing Directive. The clarification of the scope was one of the essential motivations for the review.

Related Position Papers

Environment: Response to Commission circular economy roadmap consultation [20 January 2020]

Environment: EU-wide uniform conditions for the proper quality treatment of WEEE: A call for Implementing Acts to lay down minimum quality WEEE treatment standards in strict accordance with the European standards [12 December 2019]

Environment: Evaluation of Directive 2011/65/EU (“RoHS”): Improving implementation in a Circular Economy context [6 December 2019]

Environment: Orgalim response to the public consultation on the RoHS evaluation [6 December 2019]

Environment: The European technology industries’ priorities for the sustainable use and management of water in Europe [14 November 2019]

Environment: Orgalim's response to a public consultation on sustainability requirements for batteries [27 August 2019]

Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment [26 July 2019]

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12 March 2019]

Feedback on the usability of the taxonomy - Orgalim response [25 February 2019]