Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment

Published: 26 July 2019

Policies & Issues: Environment

As regards the general concept of “eco-modulation” of producers’ fees, Orgalim together with five associations, APPLiA, DIGITALEUROPE, EucoLight, LightingEurope and the WEEE Forum, acknowledge policymakers’ good intention to reward producers for their efforts in ever more environmentally conscious product design contributing to the achievement of the targets of the Circular Economy.

By the end of the year, the European Commission will publish guidelines on the modulation of financial contributions of producers of products to extended producer responsibility (EPR) schemes to assist Member States in the implementation of the Waste Framework Directive (WFD). The associations would like to provide policymakers with the recommendations and key principles for a workable and successful modulation of producers’ fees.

The associations highlight that EPR free-riding is a serious and growing concern, especially in times of e-commerce. The undersigning associations alert policymakers that modulated fees create an additional layer of complexity in the EPR system. In setting modulated fee schemes, particular attention should continue to be paid to the implementation of the current system of EPR fees, which is heavily affected by free-riding and non-compliance all over Europe.

To read the recommendations and key principles in full, please download the position paper above.


Sigrid Linher
Director - Energy, Climate & Environment
Stéphanie Mittelham
Manager - Environment

Related Position Papers

Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database [30 June 2020]

Environment: Orgalim comments on the development of sustainability requirements for batteries under a New Regulatory Framework for Batteries [26 June 2020]

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]

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]