WEEE2: Draft Implementing Regulation establishing a Common Methodology for the Calculation of 'The weight of EEE placed on the national market in each MS' & a Common Methodology for the Calculation of the 'Quantity of WEEE Generated by Weight in each MS'
According to Article 7(1) of the Directive 2012/19/EU on Waste Electrical and Electronic Equipment (further on 'WEEE2'), member states will have two options for demonstrating compliance with the new minimum collection rate from 2019 onwards. They can either collect “65% of the average weight of EEE Placed on the Market (further on “POM”) in the three preceding years in the Member State concerned”, or collect “85% of WEEE generated on the territory of that Member State”.
Article 7(5) WEEE2 tasks the Commission with establishing common methodologies for both, the calculation of the “weight of EEE POM” and of the “quantity of WEEE generated in each Member State” by 14 August 2015.
The United Nations University (UNU) assisted the Commission in developing these methodologies. They also created the UNU-keys, which can be used to harmonise the domestic production, import and expert statistics needed for the POM calculation across member states.
Orgalime fully supports the efforts of the European Commission to establish such common methodologies. On the one hand, these methodologies are crucial to ensure a clear and harmonised implementation of the collection target in each Member State. On the other hand, it is essential that the methodologies lead to fair targets, which are based on objective, clear and transparent criteria. Member States are of course free to choose, which of the two approaches they use to demonstrate the achievement of the collection rate from 2019 onwards.
Following the Commission’s stakeholder meeting on 20 May 2015, we welcome the opportunity to provide our comments on the Draft Implementing Regulation (Draft Regulation), which has been circulated to this end. Our comments refer to three parts: First, we outline our reasons for supporting the WEEE generated approach and highlight the importance of the all actors’ concept. Second, we provide three improvement suggestions for the proposed methodologies. Third, we raise three issues, which we find require further clarification
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