Orgalime kindly requests the support of European regulators for the following key concerns on the Commission’s proposal of 3.12.2008 for amending Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE):

1. Lack of transparency: Notwithstanding certain stakeholder consultations before summer 2008, the Commission did not discuss key options chosen for the final proposal with stakeholders beforehand. It also does not support its final proposal with sound data, an implementation report or its own preparatory studies that would justify the need for fundamental changes in the directive, i.e. in the areas of financing and collection. As a consequence, we feel that the proposals are completely inappropriate and we rely on the European Parliament and Council to achieve a workable solution.

2. Producers of electrical and electronic equipment are committed to the objectives of the WEEE Directive: Producers have taken their responsibility seriously and have driven an effective and efficient implementation of the existing directive in the member states, which we will continue to do. Producers are fully committed to treat 100% of the WEEE that is handed over to them in compliance with the respective provisions of the WEEE Directive.

Orgalime therefore acknowledges the Commission’s identified outstanding issues with regards to the management of WEEE, and in particular: • To avoid improper treatment of WEEE inside the EU and illegal WEEE shipments outside the EU • To reduce administrative burden and costs without lowering environmental protection • To better harmonise and clarify the directive, i.e. in the areas of registration, reporting and scope • To bring all WEEE collected and treated into the official WEEE reporting scheme • To ensure an efficient raw material and resource management