EERA letter to European Commission COVID- 19 pandemic

27^th March 2020

The European Electronics Recyclers Association (EERA) wish to express that the industry associated with the management of waste electrical and electronic equipment (WEEE) requires greater recognition by the European Union and competent authorities during this crisis period emerging from the global COVID-19 pandemic.

EERA calls on the European Union and competent authorities from members states, the United Kingdom, Switzerland and Norway to acknowledge that WEEE management, including the collection, logistics and processing of WEEE, plays an essential role in the protection of the environment and human health, which are of utmost importance to maintain during this critical time.

The WEEE industry should be classified as an ‘essential’ sector similar to other waste industries and waste streams which are already provided such classification by some member states (e.g. the Netherlands). Therefore, EERA request that if the European Commission is drafting a list of ‘essential’ sectors, that it does not overlook the WEEE industry in this regard.

EERA must also undoubtedly raise awareness of the need to protect workers in this industry at this time and ask that competent authorities help facilitate the provision of sufficient personal protective equipment (PPE). PPE must be provided in a timely manner in order for industry to safely conduct operations in accordance with national and European requirements.

Following on from considerable internal discussion, EERA request that the following measures also be taken into consideration:

• For municipalities, it is acknowledged that adapting working rules and ensuring adequate protection and protocols are in place fall under the responsibility of the competent authorities in member states;
• Contracts with collection schemes must include temporary concessions on collections and allowances for the fluctuation of WEEE volumes;
• Intra EU waste shipments are essential given the current situation. Free movement of goods must be maintained, and validity of existing notifications should be extended. This process must be simplified without the need for original documents and/or signatures. Paper-based exchanges between facilities and carriers must be temporarily ceased due to the associated infection risk;
• International logistics need to be secured by Green Lanes, allowing wastes to be delivered to recycling facilities without unnecessary interruption and delay;
• Situations in which treatment is not possible and large volumes of WEEE must be stockpiled must be avoided at all costs. It is increasingly likely that this may occur as not every member state will have the full range of treatment options available to them for WEEE and WEEE fractions due to operational scale-back and site closures stemming from the virus. EERA request that competent authorities waive restrictions on facility storage for the duration of the COVID-19 pandemic;
• Request for state aids eligibility - The European recycling industry is, by nature, labour Falling commodity prices and lower volumes to be treated are a threat to this industry.

EERA disclose that the logistical activities associated with WEEE treatment in Europe have already been acutely impacted by the crisis and operational capabilities are being significantly tested. In many countries, rates of collection have suddenly and sharply declined. In reaction to this, a significant number of WEEE treatment facilities have had to greatly reduce their activity or even halt operations altogether. There is a dire need to support the WEEE industry in order to maintain the processing of WEEE recycling in Europe and prevent a collapse that would result in extensive impacts to the environment, human health, and most certainly, the European economy in the long term.