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.