Recast Waste Electrical and Electronic Equipment Directive ('WEEE2'): Comments on Draft Guidance Document ('FAQs')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

 

Related Position Papers

Environment: Orgalim views and recommendations on the Sustainable Products Initiative [16 November 2020]

Environment: Orgalim position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: Orgalim executive summary of the position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: 40 industry organisations call for urgent actions to postpone the legal obligations to the ECHA SCIP database [21 September 2020]

Environment: Joint industry statement on the impact of restricting primary batteries in Europe [15 September 2020]

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]