Scope is the Anchor for any Legislation – Do not Waste the Chance for a Better WEEE Directive

Published: 12 January 2011

Policies & Issues: Environment

Orgalime’s fundamental request to regulators is to ensure an EU legislation that is workable and enforceable in practice by supporting the following main proposals:

• Stick with a clearly defined scope of ten categories of WEEE covered by the Directive – the consequences of the proposal for an open scope have not been subject of an impact assessment. We would like to remind regulators that the basic aim of the directive is to deal with the growing household waste stream.

• Introduce a distinct but comprehensive set of scope exclusions, including: military equipment; equipment which is part of another type of equipment not within the scope of WEEE; fixed installations; large scale industrial tools; non road mobile machinery; any means of transport; photovoltaic modules; fixed parts of a building; filament light bulbs and implanted and infected medical devices.

• Reject any illustrative list of product examples covered by the Directive, since such a list can never be complete or follow technological developments in a timely manner.

• As this Directive is under Article 192 of the Treaty on the Functioning of the EU, it is all the more important that the scope should be clearly defined within boundaries so as to not radically increase the uncertainty which is already, today, faced by producers under the existing Directive. The clarification of the scope was one of the essential motivations for the review.

Related Position Papers

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]

Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024 [2 June 2021]

Environment: Orgalim comments on the REACH revision roadmap [1 June 2021]

Environment: Orgalim comments on the French draft decrees on the identification of hazardous substances and the provision of information identifying endocrine disruptors in products [22 March 2021]

Environment: Orgalim comments on a proposal for a Regulation for Batteries and Waste Batteries [1 March 2021]

Environment: Orgalim comments on the 1st draft delegated act on climate change sustainable activities supplementing the EU Taxonomy Regulation [18 December 2020]

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]