European Commission Call for Evidence: Strengthening the EU WEEE Framework
In October 2022, EERA contributed to the European Commission's evaluation of the WEEE Directive, drawing attention to persistent differences in how WEEE rules were being implemented across Member States. While the Directive had established an important framework for extended producer responsibility, we argued that inconsistent national approaches to collection, classification, treatment and reporting were limiting its effectiveness and creating unequal conditions for WEEE operators across Europe.
Greater harmonisation across Europe
We highlighted the lack of harmonisation between Member States, which had resulted in different requirements for documentation, reporting and enforcement. At the time, only around 45% of WEEE was being responsibly collected and treated in the EU, compared with the 65% collection target applying from 2019. We therefore called for harmonised requirements through an EU Regulation, rather than continued reliance on differing national implementation of a Directive.
Clearer scope and stronger collection
Different WEEE classifications were also creating inconsistent operating conditions. We argued that classifications should focus more on a product's content, hazards and treatment requirements, rather than primarily on size.To address leakage from compliant collection and treatment routes, we called for mandatory handover of WEEE to approved European collectors and compliant preparation-for-reuse and recycling operators. Producers and collective schemes should remain responsible for all EEE placed on the market, rather than only WEEE made available to them.
Mandatory treatment standards
Differences in national treatment requirements can create unfair competitive conditions and undermine investment in high-quality recycling. We therefore continued to call for mandatory WEEE treatment standards across Europe, helping to prevent the loss of critical raw materials and other valuable secondary materials.
Better recycling and recovery targets
EERA called for a shift away from recycling and recovery targets focused primarily on weight. Measuring tonnes alone does not provide sufficient evidence of treatment quality or demonstrate whether important materials, including critical raw materials, have been recovered and hazardous components properly removed.
We argued for targets that better reflect the characteristics of different product types and give greater consideration to performance across the waste hierarchy. Recycling and preparation for reuse should also be assessed together to provide a more meaningful picture of WEEE management.
EERA also called for an end to the use of substantiated estimates, arguing that reported performance should be based on evidence that correct treatment and recovery have actually taken place.
About the consultation response
This October 2022 submission sets out EERA's recommendations to the European Commission for a more harmonised, enforceable and quality-focused European framework for WEEE collection, treatment and recycling.
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