Joint Position Paper on WEEE Recast, 2nd Reading

In view of the European Institutions second reading on the Recast Waste Electrical and Electronic Equipment Directive, industry organisations, which represent producers of electrical and electronic equipment across all categories, call on regulators to ensure that the re-cast leads to improved environmental protection as well as greater efficiency and more effective enforcement of the Directive.

It is vital that the Recast does not create additional administrative burden, without any environmental benefit, for producers to comply with given the goals of the Recast and that they have made investments, both financial and human, in ensuring compliance with the Directive.

Industry is principally concerned with the following proposals arising from first reading:

*Extending the scope and reorganising the existing ten scope categories

*Applying the collection rate to producers and basing it on “EEE placed on the market”

*Extending producers' financing obligations for collection beyond agreed collection points

*Limiting legal shipments of used professional EEE to shipments for direct reuse or under warranty only

*Unsatisfactory provisions regarding transparency of collection/recycling costs having a separate preparation for reuse target

*The broad definition of WEEE from private households

*The lack of clarity on how the producer will be defined in the directive and how a workable registration model will be ensured

*Certain details of the proposals to develop eco-design and treatment standards