WEEE - Main Comments on Commission Recast Proposal for Directive 2002/96/EC (WEEE)

Published: 16 February 2009

Policies & Issues: Environment

Orgalime kindly requests the support of European regulators for the following key concerns on the Commission’s proposal of 3.12.2008 for amending Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE):


1. Lack of transparency: Notwithstanding certain stakeholder consultations before summer 2008, the Commission did not discuss key options chosen for the final proposal with stakeholders beforehand. It also does not support its final proposal with sound data, an implementation report or its own preparatory studies that would justify the need for fundamental changes in the directive, i.e. in the areas of financing and collection. As a consequence, we feel that the proposals are completely inappropriate and we rely on the European Parliament and Council to achieve a workable solution.


2. Producers of electrical and electronic equipment are committed to the objectives of the WEEE Directive: Producers have taken their responsibility seriously and have driven an effective and efficient implementation of the existing directive in the member states, which we will continue to do. Producers are fully committed to treat 100% of the WEEE that is handed over to them in compliance with the respective provisions of the WEEE Directive.


Orgalime therefore acknowledges the Commission’s identified outstanding issues with regards to the management of WEEE, and in particular:

• To avoid improper treatment of WEEE inside the EU and illegal WEEE shipments outside the EU

• To reduce administrative burden and costs without lowering environmental protection

• To better harmonise and clarify the directive, i.e. in the areas of registration, reporting and scope

• To bring all WEEE collected and treated into the official WEEE reporting scheme

• To ensure an efficient raw material and resource management

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]