Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment

Published: 26 July 2019

Policies & Issues: Environment

As regards the general concept of “eco-modulation” of producers’ fees, Orgalim together with five associations, APPLiA, DIGITALEUROPE, EucoLight, LightingEurope and the WEEE Forum, acknowledge policymakers’ good intention to reward producers for their efforts in ever more environmentally conscious product design contributing to the achievement of the targets of the Circular Economy.

By the end of the year, the European Commission will publish guidelines on the modulation of financial contributions of producers of products to extended producer responsibility (EPR) schemes to assist Member States in the implementation of the Waste Framework Directive (WFD). The associations would like to provide policymakers with the recommendations and key principles for a workable and successful modulation of producers’ fees.

The associations highlight that EPR free-riding is a serious and growing concern, especially in times of e-commerce. The undersigning associations alert policymakers that modulated fees create an additional layer of complexity in the EPR system. In setting modulated fee schemes, particular attention should continue to be paid to the implementation of the current system of EPR fees, which is heavily affected by free-riding and non-compliance all over Europe.

To read the recommendations and key principles in full, please download the position paper above.


Sigrid Linher
Director - Energy, Climate & Environment
Stéphanie Mittelham
Manager - Energy and Environment

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