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There is theory and then there is practice. European Commission authorities responsible for the Waste Electrical and Electronic Equipment (WEEE) directive are hearing that loud message from municipal governments, state registry agencies, manufacturers, industry bodies and NGOs as it conducts a review of the product takeback directive.
The WEEE review began last summer and is expected to conclude next year with proposals to revise the legislation. The Commission invited input, and they're getting it.
Manufacturers are standing shoulder-to-shoulder with their traditional adversaries to impact the review. Companies including Samsung, Acer and Motorola have joined forces with organizations such as Friends of the Earth Europe and Greenpeace to write a complaint about what they see as the directive's key implementation failure — not promoting eco-design.
Iza Kruszewska, a Greenpeace International toxics campaigner based in London, said the eco-design failure lies in a misunderstanding that needs to be clarified.
According to WEEE, historical waste — all the old electronics that was around before the August 13, 2005 WEEE deadline — is a collective responsibility. Manufacturers pay for recycling all the old waste, regardless of brand, according to their current market share.
But future waste, electronics put on the market after the deadline, is the responsibility of each individual producer, in line with the Individual Producer Responsibility (IPR) principle the WEEE directive calls for. The idea is to motivate companies to compete on design innovations for easier and cheaper recycling.
Sounds clear enough, but when WEEE was handed down from Brussels to be written into the laws of each of the 27 member states, only 11 countries spelled out the distinction between historical and future waste, Kruszewska said.
"The danger is that the states will go on forever with collective responsibility," she said. "Then manufacturers who make changes to products to improve recyclability will not be rewarded."
IPR is a hot issue that is uniting many groups. But makers of large household goods are lobbying hard against it because their appliances are designed to last more than a decade, said Hans Jochen Lueckefett, managing director of 1WEEE Services (Boeblingen, Germany), a pan-European compliance scheme. "They're saying it's ridiculous to make a design-for-recyclability investment when ROI is more than ten years away," Lueckefett said. "Most countries have followed their argumentation."
Eco-design of course is mandated by the imminent Energy using Products (EuP) directive, expected to launch in August. But the EuP targets design for energy efficiency and not recyclability, Kruszewska added.
Registration causes additional headaches
Moving beyond IPR, other implementation problems stem from the mish-mash of registration procedures across the EU.
Viktor Sundberg, vice president of environmental and European Affairs for Electrolux in Brussels, cited the inefficiencies in dealing with national registration bodies, which add time and money.
Companies need to register in each member state the quantity of products they put on the market. But the registry and format varies by country. Some ask to define quantity by categories of equipment, others by volume or weight. Layered on top of these varying requirements are language and bureaucratic differences.
In addition, when waste moves between countries, responsibility for recycling changes. "These registration bodies need to talk to each other and compare data, but they can't because the [process] is not the same in each country," Sundberg said.
Recycling costs also vary widely by country, said Christof Delatter, coordinator at the Association of Flemish Cities and Municipalities in Brussels, which works with a network known as ACR+ that is addressing the "confusing and inconsistent" WEEE implementation.
According to Delatter's statistics, recycling a digital camera in Switzerland costs 1 euro. In Germany, recycling the same camera costs 1 euro cent. "The difference is a factor of 100 and has nothing to do with the efficiency of the operation," Delatter said. "In Germany, local infrastructure has to be paid by municipalities, which in our opinion is not compliant with the directive."
In some countries, such subsidies are hidden, Delatter added. "You don't really know how much money goes from local and central authorities into these takeback systems and that makes it very difficult to compare efficiency of the different systems."
Compliance schemes themselves also want WEEE revisions. Hans Korfmacher, president of the European Recycling Platform, a pan-European WEEE compliance scheme founded by manufacturers, said the unharmonized procedures extend to the permit process for compliance schemes.
Germany, for example, has one central agency and a simple permit procedure. In Spain, a WEEE services company has to fill out a stack of paperwork for each of the 19 regions and wait for all the approvals. "[The bureaucracy] is blocking competition between compliance schemes," Korfmacher said.
The bureaucratic burden also translates into additional costs. ERP's recycling costs for a laptop in Spain, for example, are about four times higher than in countries with the most efficient permit procedures, he said.
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