Joint Letter on Proposed Unitary Own Resource on Non-Collected E-Waste

To: Piotr Serafin, Commissioner for Budget, Ambassador Søren Jacobsen

Cc Jessika Roswall, Commissioner for the Environment

Dear Commissioner Serafin, Dear Ambassador Søren Jacobsen

The Electrical and Electronic Equipment (EEE) producer industry stands firmly alongside the EU in working to achieve ambitious climate and environmental protection goals, significantly contributing to saving energy, resources and greenhouse gas emissions. While we support the EU's efforts to establish a suitable legislative framework for environmental and climate protection, we are writing to you today to express our profound concern regarding the proposed unitary own resource of €2/kg on non-collected e-waste within the Multiannual Financial Framework (MFF), the EU’s long-term budget. This planned initiative is an inadequate answer to the e-waste collection objectives of the EU and requires urgent correction to effectively promote environmental protection. We believe this measure is ill-conceived and risks creating significant market fragmentation, excessive financial and administrative burden, while unsupported by robust, harmonised data.

Solid indisputable data is a basic legal requirement for any financial levy. Taken together, these shortcomings risk significantly weakening the sector’s competitiveness, a critical element for a thriving European circular economy. We urge policymakers to reconsider this approach and suggest that a more constructive and effective path lies in adapting the existing regulatory framework.

The current rules governing e-waste in the EU are set out in the Waste of Electrical and Electronic Equipment (WEEE) Directive. This legislation places responsibility on producers to finance the collection, treatment and environmentally sound disposal of e-waste. It also sets national collection targets and recycling/recovery requirements across Member States.

While the Directive created a solid foundation, it has clear limitations: collection targets are not being met, enforcement is uneven, and many actors involved in e-waste handling are not properly regulated or held accountable. The European Commission plans to revise the WEEE Directive as part of the Circular Economy Act, expected in late 2026. This is a real opportunity to strengthen the system and boost both collection volumes and recycling quality.

We recommend that EU policymakers:

● Properly enforce existing legislation and involve all actors across the value chain.

● Prioritise nurturing a framework that fosters investments in recycling infrastructure and technologies.

● Prioritise data standardisation across Member States and reform the Eurostat statistics collection system.

● Calculate the collection rate on a reliable basis that takes into account different periods of use or waste available for collection. Work towards making the amount of generated WEEE known.

● Focus on the upcoming revision of WEEE legislation within the framework of the Circular Economy Act, as it offers a genuine opportunity to rethink the Extended Producer Responsibility principle based on the ‘all actors’ principle. In this context, the producers and manufacturers industry has outlined a set of key challenges along with proposed solutions, which should serve as a foundation for shaping a stronger and more viable EU circular economy.

● Ensure any proposal for financial instruments must be preceded by a comprehensive impact assessment that must, at a minimum, clearly demonstrate:

○ The effectiveness in improving the sector’s circularity and WEEE collection.

○ The meaningfulness of the level of the financial levy.

○ The need for a novel approach and an EPR financing model involving all actors.

○ The requirement to hypothecate funds from any proposed own resource for reinvestment into the existing WEEE system.

○ The impact on the European economy, consumers, and companies.

Our concerns are thoroughly detailed in the annex below, highlighting the significant negative implications for consumers, producers, the e-waste management ecosystem, and overall European competitiveness.

We firmly believe that the proposed own resource would be ineffective, run counter to ongoing critical EU legislative initiatives, and may lead to higher consumer costs and unjust measures instead of improving WEEE collection. Therefore, we urge the European Commission to withdraw this proposal.

We stand ready to collaborate with policymakers and interested stakeholders to find genuine solutions that will lead to a more circular economy without penalising producers and undermining Europe's industrial base.

Yours sincerely,

APPLiA, DIGITALEUROPE, EHI, EPTA, ERP, EucoLight, ITI, LightingEurope, Orgalim, WEEE Forum