Waste electrical and electronic equipment (WEEE)

AEPSA A Associação dos Empresas Portuguesas para o Sector do Ambiente, hereinafter referred to as AEPSA, is a business association, established in 1994, which represents and defends the collective interests of private companies intervening in the environmental sector.

Filed in Portuguese · English published by the European Commission

European Recycling Platform (ERP) welcomes the opportunity to comment on the European Commission's proposal for a Directive amending the Waste Electrical and Electronic Equipment (WEEE) Directive to address the implications of the European Court of Justices judgment (Case C-181/20) on the financing of the collection and treatment of WEEE from users other than private households.

Although the European Environmental Bureau (EEB) respects and appreciates the need for legal certainty in accordance with EU law, the decision to revise the Waste Electrical and Electronic Equipment Directive to exempt certain products from proper collection is highly concerning in economic and environmental terms.

Stanovisko Hospodářské komory České republiky k Návrhu SMĚRNICE EVROPSKÉHO PARLAMENTU A RADY, kterou se mění směrnice 2012/19/EU o odpadních elektrických a elektronických zařízeních (OEEZ) HK ČR upozorňuje na nutnost zakotvit v návrhu směrnice přechodné ustanovení, které umožní České republice zachovat dosavadní režim plnění povinností k solárním panelům uvedeným na trh v období od 13. srpna 2012 do 1. ledna 2013.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ECOS understands the legal context of the Commissions proposal for targeted amendments of the WEEE Directive. But such weakening of EU e-waste rules seems even more a missed opportunity to perform its complete overhaul for PV and all EEEs. It also goes against the EU ambition to recover important materials, including Critical Raw Materials, in line with the EU 2023 CRM Act.

I understand that the proposed amendment is to give effect to a decision made in the ECJ but I have two brief comments to make: Firstly, I would question the need to differentiate between B2B and B2C for PV panels for the purpose of the amendment.

I find it a good thing to review certain parts of the directives to reflect more closely the reality on the ground, environmental issues and manufacturers’ constraints, particularly in the case of photovoltaic panels. On the other hand, I find that these changes too often lead to problems raised after launch, use of products and end-of-life management.

Filed in French · English published by the European Commission

We support the Commission in the amendments proposed. EERA is a non-profit organisation and is the voice of WEEE recycling in Europe being the professional association for the re-use, recycling and re-processing industry. Our vision is for a resource efficient economy where WEEE is managed as a resource and is returned into the economy as a secondary raw material or as equipment prepared for re-use.

It is interesting to see PV panel EEE and WEEE being explicitly included in this way in the proposed amendments. I realise that the amendments are being proposed to specifically address a decision by the CJEU but is this an opportunity to include more changes specifically related to PV panel EEE and WEEE? The use of PV panels is increasing.

In the light of anticipated lifetime for all electronic equipment for consumers, being less than 10 years, all equipment now being taken out of service and put out for waste is deemed to be manufactured after the 2005 date set in standard EN 50149:2022 for when the black bar underneath the crossed out wheelie bin shall be included.