[Christian Verschueren, Director General of EuroCommerce, gives his view on recent modifications to the electronic waste directive.]

The primary aim of the directive on Waste of Electrical and Electronic Equipment (WEEE) is to minimise the impact of electrical and electronic goods on the environment. It seeks to do this by increasing re-use and recycling and by reducing the amount of WEEE going to landfill. This is an aim we in the commerce sector support whole-heartedly. We also support the general ambitions of the current recast of the directive, contained in the report adopted by the Parliament’s environment committee last month.

Commerce has always been a fierce believer in the internal market and has consistently encouraged efforts to increase the free movement of goods. We therefore welcome those amendment adopted by the committee which are business-friendly and will contribute to the better functioning of the internal market. 

To date, the WEEE directive has brought tangible improvements on the environment front. Collection and recycling rates, for large appliances in particular, have increased substantially.  However, small-volume WEEE remains a challenge. Many small appliances escape the traditional WEEE collection schemes and are sent to landfills. Increasing their collection rates depends on a number of different factors, including the quality of available waste management infrastructure and consumer awareness. 

The recast is attempting to increase the collection and recycling rates of very small volume WEEE by establishing a ‘one-size fits all’ system. Again, we applaud the aim, but we cannot agree with the method. 

The European Parliament is suggesting a mandatory in-store take-back for all small volume WEEE. This would mean that retailers of EEE would be obliged to take back very small volume WEEE, free of charge, even if the customer does not buy a new appliance. This is different from the current system. Under the present directive, take-back of WEEE occurs on a 1:1 basis. This means that  retailers have to take-back old appliances, only when it corresponds to the type they sell, and only if the consumer buys a new one.

Under the new proposal, however, the small WEEE which the retailer would be obliged to take-back is not necessarily related to the equipment sold. For example, if a consumer goes to buy a mobile phone charger in a shop which only sells phones and appliances, he or she could at the same time return an old, broken hairdryer.  

This may sound a very easy and appealing option. Effectively, it converts all electrical goods shops into collection points for all small electrical waste. However, there are many problems and risks which have not been fully examined. 

The personnel in all these small shops would have to store and dispose of waste appliances with which they are not familiar and they do not sell. Staff would therefore have to be trained; time and resources would have to be given to these tasks. This would be very costly and, we argue, highly inefficient. In countries where the collection infrastructure is not advanced, retailers may be left unable to dispose of the collected WEEE. Therefore, ensuring that ultimate disposal is safe and environmentally adequate would be problematic. 

In addition, WEEE statistics show that in countries without a retail take-back obligation, the percentage of returned and recycled products can be higher than the EU average if the system works well. This is the case in Germany for example, where collection of small household appliances was 55% in 2008. A mandatory EU take-back by retailers would duplicate the existing schemes which enable high collection rates, in such countries.

This proposal would also entail distributors taking over responsibilities which properly lie with the producer. This violates the basic internal market principle that each operator is responsible in relation to its respective role in the supply chain. 

A single solution for all is always attractive. But, in the real world, it is not always the best solution. For small WEEE, for all the above reasons, a single solution would be positively detrimental. The reality in the EU is that the collection of WEEE varies substantially from country to country. The recast directive should therefore focus on the desired outcome – how to collect a greater proportion of WEEE. Given their disparate situations and needs, it should be left to the member states to decide at national level how best these targets should be met.