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Brussels, 14/02/2001


Euro Coop's Comments to the Commission's Proposal for a pair of two Directives on Waste Electrical and Electronic Equipment (COM (2000) 347)


Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.

Euro Coop welcomes the European Commission's Proposal for a pair of two Directives on Waste Electrical and Electronic Equipment (WEEE) (COM (2000) 347). However, Euro Coop is disappointed to see that the ambitions of the Commission have weakened compared to previous drafts.

Euro Coop believes it is necessary that the proposal focuses on how to promote a more sustainable production and consumption in order to solve the problems connected to WEEE. The solution is not only to propose end-of-life solutions when damage has already been done. More emphasis should be put on preventing the use of hazardous substances in electrical and electronic equipment. Therefore, Euro Coop calls for the following to be included in the Proposal:

  • Both Directives should be based on the Treaty's Article 175.
  • Standards for greener product manufacture.
  • The issues of electronic shopping and spare parts.
  • The producer responsibility should be strengthened.
  • Waste collection facilities should be set up by the local authorities in each Member State.
  • The precautionary principle should apply on the use of hazardous substances in products. In addition, a tax should be put on the use of the substances in order to reduce their use.
  • Better consumer information.
  1. The Legal Basis:


    2. As the proposal stands now the two Directives are based on two different EU Treaty articles. The draft Directive on WEEE is based on the Treaty's article 175 whereas the draft Directive on the restriction of the use of certain hazardous substances on electrical and electronic equipment is based on article 95. In Euro Coop's opinion the pair of two Directives should be based on article 175 of the Treaty and not article 95 in order to allow the Member States to set stricter restrictions on hazardous substances than would otherwise be the case.

  2. Standards for Greener Product Manufacture:


    3. Unfortunately, references to standards for greener product manufacture and design will be addressed in a separate proposal for a draft directive in stead of incorporating it into the present proposed pair of Directives. Euro Coop believes that by including the issue of greener product manufacturing, a more ambitious and overall approach to the problems connected to WEEE would have been made. As the Commission's proposal stands now the problems are dealt with far too ad hoc and isolated. Euro Coop would like to see the issue of green product manufacture addressed. It is vital in order to ensure sustainable development. As such, incentives should be given for producers to develop greener products. For instance, by finding a way to integrate the environmental costs into the price of the product. In that way allowing for fairer competition between less and more environmentally friendly products. At the same time it will allow the consumers to make a choice and to develop a more sustainable consumption pattern.

  3. Electronic Shopping and Spare Parts:


    4. The two issues: electronic shopping and spare parts to electronic products are not dealt with in the proposal. Euro Coop believes they must be dealt with since electronic shopping might turn into a loophole for producers as they would not have any responsibility to pay the costs for waste disposal unless the proposal's legislative measures is. As well, it should be ensured that spare parts of an electronic product are included in the proposal's legislative measures, as is the case for the product itself. It is important to include spare parts as they are frequently replaced instead of the product itself. The same kinds of problems will arise in connection with the waste management as for the product itself. As the proposal stands now it is not very clear if spare parts are included or not.

  4. Producer Responsibility:


    5. The question of producer responsibility should be strengthened in the proposal. The producers should be held directly financially responsible for the collection of electronic waste from private households, as well as, they should be held individually responsible for future electronic waste in order to promote a more sustainable design of products. Since it should not be profitable for the producer to pollute. Though, the producers should be held collectively financial responsible for historical waste (waste from products put on the market before entry into force of this legislation). However, it should not be possible for the producers to put the extra costs for the financing of the collection system on the price of their products, so the consumers end up paying the price. If this does become the case the fee, the consumers pay for the recycling of the product, should be visible and differentiated in order to reflect the product's environmental burden.

  5. Waste Collection Facilities:


    6. The collection facilities should be set up by the local authorities in each Member State in order to take back old items. As the proposal stands now, the consumer has the right to leave their old item with the shops when buying a new one. However, it should not be the responsibility of the shops to get rid of the old items. First of all, because smaller shops would simply not have the financial and the personnel resources to do so. Secondly, shop workers would be exposed to hazardous substances, since they do not have the knowledge or equipment to safely handle those kind of items. Besides, shops would not have sufficient storage facilities for larger appliances until they can be collected. Therefore, it should not be made compulsory for shops to take back old items. Euro Coop thinks that the best system would be a system set up jointly by the local authorities and the producers in each Member State to secure that the electronic waste is handled properly. If the shops are going to be responsible it would require additional resources allocated to them in terms of financial support, like refunding the shops' collection costs, and education of staff.

  6. Hazardous Substances:


    7. Euro Coop believes that the precautionary principle must apply whenever there is a potential risk to human health or to the environment. In these cases, the use of the substance must be banned or phased out immediately. In addition, one way to reduce the use of hazardous substances could be by taxing the producers for the hazardous substances used in the products. The tax should reflect the substances' environmental impact in order to make the producer reduce and/or substitute the use of them.

  7. Consumer Information:


    8. The consumer should be informed about the hazardousness of waste in order to promote a more sustainable consumption pattern, not only about the collection system for electronic waste. Therefore the label requirements on products should not only be restricted to the symbol presented in the Commission's proposal, that the product should be returned, but also inform if the product contains any hazardous substances. In addition, general information on WEEE could be given in the shops, where the consumer buys the product, in the form of leaflets, information campaigns etc. supported by the Commission in terms of finances and updated information.