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APPLiA feedback to the Commission's evaluation of the WEEE Directive

Policy papers 22 Sep 2023

The evaluation of the WEEE legislation provides an opportunity to assess fully if the current WEEE Directive remains fit for purpose. Much has changed in the world of recycling e-waste since the introduction of the first WEEE Directive almost two decades ago. Producers and Producer Responsibility Organisations (PROS) have made considerable investments ensuring the collection, recovery and recycling of WEEE. Better measures to properly report and recycle WEEE and closing the gaps in raw materials’ data information and collection is the first and fundamental step to improve knowledge on the quality and quantity of recovered secondary raw materials from WEEE. 

As a sector with over 20 years experience with WEEE requirements, we look forward to working with the Commission and the consultants conducting the evaluation study to investigate the challenges and the potential future solutions to further improve the level of WEEE collected and properly treated and recycled across the EU.

Key messages

  • ➔  All WEEE actors involved in the collection, transportation, sorting and treatment should have a responsibility under an effectively enforced legislation to ensure that all WEEE is accounted for and treated properly.

  • ➔  The way the collection target is set and calculated needs to be reevaluated as it is not working. Factors that influence collection should be considered such as a product category's average or expected lifetime, trends and market developments, consumer behaviour and the value of secondary raw materials.

  • ➔  ThereshouldbeaharmonisationofWEEEtreatmentacrosstheEUalignedtoEN 50625 / EN 50614 standards as the mandatory reference. Recycling & Recovery ambitions should focus on improving the quality of secondary raw materials to go back into material loops in the circular economy.

  • ➔  Any future revision of WEEE legislation, should not jeopardise the well-functioning systems set up so far in Member States, but rather build on the many good practices demonstrated in raising the bar on WEEE management. This good work should form the base of a future harmonised approach to handling WEEE, whether that be a revision of the Directive or moves towards a Regulation.

  • ➔  WEEE legislation should focus on increasing proper collection and recycling. Preventing/ delaying waste from arising and working towards a circular value chain should be handled in the Ecodesign for Sustainable Products Regulation (ESPR). All product ecodesign requirements should exclusively be regulated under ESPR.

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