‘Harmonisation needed’ in e-waste Directive (WEEE)

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The EU’s WEEE Directive to collect and recycle electronic waste has created a heavy administrative burden for companies that is exacerbated by the multitude of national systems, says Kirstie McIntyre from HP.

As a large maker of consumer electronics, how is HP affected by the WEEE directive?

The Directive applies to most of HP’s products. We are now contributing to the implementation process in each member state where the company has a presence.

Two of the largest markets for WEEE recycling are Germany and Austria. Austria has been operational since August 2005 and Germany since March 2006. 

HP is also particularly active in Ireland, which is considered as one country leading the implementation of the WEEE Directive. Between August 2005 and May 2006, 21,500 metric tonnes of all waste covered by the Directive, including washing machines, fridges and electronic equipment, was collected. This is equivalent to 6.8 kg per inhabitant and exceeds the WEEE Directive target for the first year by 170%.

Can you give an estimate of the costs so far? 

In 2006, HP published data showing the real costs of implementing the WEEE Directive for consumers in a sample of European countries. 

The research demonstrated that in some countries recycling costs in relation to the end-product price for consumers are lower than initially predicted and feared.

The study also found that in countries where there is a more competitive environment for electronics-recycling providers, the take-back and recycling costs of retired electronic equipment are lower. Costs are higher in countries where there is no competition and only one recycling provider for industry to work with.

For example, Austria, Germany and Spain possess relatively new, but highly dynamic, take-back and recycling systems with strong market competition, and are enjoying costs of just a few euro cents per product.

How does the producer responsibility work in practice? 

There is a common misunderstanding that Individual Producer Responsibility (IPR) implies that each producer needs to have a separate infrastructure for the collection and treatment of only their own brand appliances. 

This is not the case. Collective recycling systems can be arranged to encompass individual financial producer responsibility. There are collective recycling systems operating today that have elements of individual financing and even physical handling.

In 2004, HP, Braun, Electrolux and Sony established the first pan-European take-back and compliance system for used electronic products. The European Recycling Platform (ERP) will enable member companies to fulfil product take-back obligations mandated by the WEEE Directive at a competitive cost, benefiting customers and the environment. In Austria, France, Germany, Italy, Ireland, Poland, Portugal, Spain and UK, ERP will be HP’s preferred recycling system. In the other EU countries, HP will join a national compliance system or another compliance system authorized for that country.

More generally, we believe that Individual Producer Responsibility (IPR), the ability for individual producers to be responsible for their respective products, is the best way to promote eco-design in products.

The principle of IPR provides a competitive incentive for producers to design their products so that they are easier and therefore cheaper to recycle.  IPR also encourages innovation and competition between companies over how to manage the end-of-life phase of their products.

HP is currently working with other producers, academics and technical specialists to identify, explore and develop practical solutions to IPR. For example, HP has joined Greenpeace, 21 electronics sector firms and 11 other organisations calling for better support across Europe for companies that are working to design environmentally friendlier products that do not harm the environment after disposal, during their recycling. 

What is your assessment of the state of implementation of the WEEE directive? Are EU countries applying it in a consistent way? Has it created problems for you?

Currently, the system creates a heavy administrative burden for companies, which is exacerbated by the multitude of national systems.

Ideally, manufacturers could provide data in the same format and frequency in all member states. Such an approach would also allow for easier comparison between the different markets at an EU level. 

The Directive is currently undergoing a review. What are your basic recommendations to improve its operation? 

Only a handful of countries have practical experience of operational recycling systems within the WEEE framework. As a result, we believe it is somewhat early to evaluate the Directive and comment on whether the existing framework is broadly workable. 

Notwithstanding, HP believes there are three fundamental points which must be considered as part of the review for the Directive to achieve low cost recycling for all customers.

1) HP would like to see the Directive fully implement IPR as it intended through the transposition to member-state legislation. HP believes that the spirit of IPR has been lost though the implementation process in many cases.  Most countries in Europe have been unable to reach a sensible working system for WEEE which implements IPR in the way intended by the Directive.

HP urges the EU institutions and the member states to ensure that IPR as established by Article 8.2 of the WEEE Directive, is correctly transposed and implemented in national legislation. Eleven Member States (Bulgaria, Denmark, Estonia, Finland, France, Greece, Latvia, Portugal, Slovenia, Spain, UK) have failed either to transpose or implement the provisions of Article 8.2.  

Although the law obliges manufacturers to take individual responsibility for financing the recycling of their products put on the market after August 2005, producers are collectively responsible for their end-of-life products in these 11 countries. As a result, the incentive to encourage producers to focus on design for recycling is absent, jeopardising the attainment of the Directive’s objectives.

2) HP would like to maintain that the Directive’s implementation allows for full competition. HP’s experience so far with countries implementing WEEE has proven that those countries with competition result in lowest cost of product recycling. 

There are two areas within the system where competition is important. Firstly, there should be a choice of compliance scheme for producers like HP to join. This is why HP founded the European Recycling Platform (ERP), to give HP and other producers greater choice in how they comply with their WEEE obligations. The ERP is currently running take-back and recycling operations for waste from electronic equipment in countries such as Austria, Ireland, Portugal, Germany and Poland. 

Secondly, competition amongst recyclers should be encouraged, which is done by providing them with more than one customer (ie multiple- compliance schemes). Market forces in both areas drive innovation in recycling techniques and logistics and therefore the cost of recycling is subject to the same price pressures that other product costs have. 

3) As mentioned already, HP sees a need for a harmonisation of the data and reporting requirements across EU member states. 

Reporting is an essential part of the implementation of the WEEE Directive. As more and more countries create and complete WEEE registries, companies such as HP have to face 27 different registration procedures, 27 different reporting structures and 27 different versions of auditing.

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