EucoLight complemented its response to the public consultation questionnaire with a position paper, pointed out several issues that need to be addressed in the context of the revision of the WEEE Directive, while making a series of recommendations.
Our recommendations in brief:
- Overall, the Directive has been effective to reach its objectives but more harmonisation in some areas is required.
- Ambiguities on (W)EEE definitions for lighting must be addressed.
- Subcategories for lighting must be harmonised in the EU.
- Extended producer responsibly: same rules for all actors and for a level playing field.
- The non-compliance of EEE sold through online marketplaces must be tackled.
- WEEE collection: consideration for waste available for collection.
- The benefit of eco-modulation of the fees is questionable.
- Linked EU legislation should be aligned and non-contradict themselves. The WEEE Directive should only focus on the collection, transport, and treatment of the WEEE.