Recast Waste Electrical and Electronic Equipment Directive ('WEEE2'): Comments on Draft Guidance Document ('FAQs')

Published: 30 August 2013

Policies & Issues: Environment

Orgalime thanks the Commission for both, the possibility to comment on the Draft Frequently Asked Questions Document on Directive 2012/19/EU, and for tabling a draft, which we generally consider a largely pragmatic, well-structured and comprehensive basis for effectively clarifying certain aspects of the Directive and helping producers in their preparations for compliance.

Orgalime expresses its explicit support for the following sections of the draft FAQs:

  • The draft Q&As provided regarding the appointment and possible mandate of an authorised representative (Q 1.32 and 1.33)

  • The draft Q&As provided regarding separate collection/collection rate: we explicitly welcome the approach of including all routes and flows of WEEE for the future implementation of the Directive (Qs 1.19, 1.25 to 1.29). This will strengthen the environmental objectives of the Directive and the Commission’s wider resource efficiency policy. While we suggest removing the last paragraph of Q 1.23, we also welcome that Member States have been confirmed as the responsible addressees of the target in this entry.

  • The draft Q&As provided to secure a European approach to the marking obligations to provide information to treatment facilities (Q. 1.31).

  • The draft Q&As regarding annex VI on minimum requirements for shipments, including the suggested interpretation of certain derogations and documentation requirements in case of legal shipments (Qs 1.38, 1.39, 1.45).

  • Most parts of the draft Q&As regarding the understanding of the scope during the transition period, including the definition of “dependent”, the continuation of the existing ten scope categories during transition period, the notion “specifically designed” and exclusions of equipment that uses electrical energy only for support or control functions (Q 1.4, 1.12, 1.13, content of Q 1.3, appendix/part 2/criterion 2).

  • The draft Q&As provided regarding reuse (Q1.22).

 

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Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]

Environment: Joint industry position paper on the concept of Essential Use [3 November 2021]

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]

Environment: Financing key enablers of the green transition: Orgalim position on the EU taxonomy for sustainable activities [6 October 2021]

Environment: Orgalim response to the consultation by the Platform on Sustainable Finance on EU taxonomy [5 October 2021]

Environment: Joint statement on the need for a transition period for the implementation of the Batteries Regulation [28 July 2021]

Environment: Orgalim input to the European Commission consultation on the Revision of the Urban Waste Water Treatment Directive [20 July 2021]

Environment: Orgalim position on the Sustainable Products Initiative [8 June 2021]

Environment: Orgalim position on draft reporting rules for companies under the EU Taxonomy Regulation [2 June 2021]