Waste Group

The Waste Cluster primarily deals with:

WEEE

The new WEEE Directive creates an opportunity to improve the performance of collection and treatment in Europe and the reporting of data pursuant to such operations. The Directive lays down new and ambitious rates for the collection and treatment of WEEE. By 2019, Member States are required to demonstrate achievement of a minimum collection rate annually of either 65% of equipment sold in the preceding 3 years, or 85% of WEEE generated.

Currently in most Member States the collection rate based on official data of WEEE separately collected by systems set up by Producers is on average 1/3 of electronic and electrical equipment sold. However, recent research in several Member States has revealed that there are large flows of WEEE beyond the Producer take back systems which are collected and recycled for a profit. Research has demonstrated that in addition to this 1/3 managed by Producer take back systems, on average, a further 1/3 is also collected and treated by treatment operators. So in fact 2/3 of the WEEE is being treated by treatment operators.

In order for Member States to demonstrate achievement of the minimum collection rates it will be necessary to collect information of all flows of WEEE irrespective of whether it was handed over by producer take back systems or by third party collectors. 

The position of DIGITALEUROPE is that all permitted WEEE treatment operators must report on all WEEE received, originating from business-to-business users as well as private households, through take back systems, municipalities or other parties, all being counted towards the achievement of the minimum collection rate.

Proper treatment based on uniform harmonised standards promotes that the recycling and recovery quotas in WEEE treatment are met. Therefore we welcome the mandate of the European Commission given to the European standardisation organisations to develop European standards for the treatment of WEEE and that those standards shall reflect the state of the art. We believe that Member States and the Commission must promote minimum quality standards for collection and treatment of WEEE pursuant to article 8.5 adopted by CENELEC. These Standards must be harmonised in Europe to prevent 28 different standards. The Commission must adopt an implementing act that ensures uniform conditions for the collection and treatment of WEEE.

Transborder Shipments for Repair

Trans-border shipments for repair allow complex capital equipment to be repaired and reused, and sometimes upgraded, thus giving the equipment a longer lifetime. Early waste generation is prevented, in line with the waste hierarchy. If the electronics industry was to ship used products as hazardous waste, this would be an extremely burdensome operation costing up to 50% more compared to shipping as non-waste. It is essential that the Basel Convention Technical Guidelines allow for the shipment as non-waste of used products and parts for testing, repair and refurbishment to centralised repair facilities which are very often established in "non-OECD" countries. Otherwise, new parts instead of refurbished parts will be used for repair, dramatically increasing the cost.

Given that repaired products compete with new products, members of DIGITALEUROPE fully anticipate that the increased cost for repairing these products, which for most multinationals involves utilising a regional network of specialized repair hubs, would render their repair / refurbishment / remanufacturing economically unviable. Customer and producer preference would be given to “replacement by new product”. Rather than being shipped and repaired, these products will be scrapped and recycled, a high volume of functioning equipment (both near-new and older) will enter the waste stream prematurely and unnecessarily.

Significant amounts of used products / service parts are shipped for repair to highly specialized regional and global repair hubs. If these products have to be shipped as waste / hazardous waste their repair would become economically unviable. Working on the premise that the circular economy is the political objective, the prolonging of product lifetimes of complex high value products becomes a condition sine qua non. This requires in turn the permission to ship used EEE across borders.

Batteries

At DIGITALEUROPE we believe there is clear justification as to why certain integrated batteries are used and why their removal from appliance should be performed by independent qualified professionals rather than end-users. These include considerations around safety, functionality and quality:

  • Safety of products throughout their entire life cycle: removability by professional services significantly reduces the likelihood of mistreatment of (specifically compact) products during the battery removability process (e.g. static discharge, short circuits or mechanical damage, etc.). Harm to untrained persons (e.g. consumers) from direct contact with a charged battery cell is prevented as well, including any danger of an unwanted chemical and/or strong thermal reaction or electric shock due to puncturing or damaging the battery.
     
  • Future product designs and material efficiency: innovation is at the heart of the digital technology industry which is clearly moving towards more wearable, bendable, flexible products. These new product concepts rely upon an efficient integration of all components, including batteries. From a material efficiency point of view, externally accessible batteries risk leading to bulkier products in that the battery would need to be compartmentalised and designed to incorporate additional safety requirements for international regulatory compliance.
     
  • Products’ performance and reliability: reliability very often depends on battery’s integration, in particular for those products which are exposed to high levels of shocks and vibration when in use and/or are used in a humid environment which makes water resistance a key feature (e.g. electronic toothbrushes, shavers, outdoor GPS orienteering devices, etc.). Improper repair of such products can result in e.g. faulty waterproof seals, which can lead to irreparable damage to the product and may expose the consumer to safety risks as mentioned above.
     
  • Proper management of waste batteries: battery collection rates across the EU indicate that consumers still dispose of their batteries through the normal household waste stream. Certain batteries, especially if damaged, present a safety risk when improperly stored and/or handled. This is especially true for Li-ion batteries, which are classified as dangerous goods under international transport regulation (e.g. ADR). Consumers, unlike “qualified professionals”, may be unaware of the packaging, disposal, and transportation requirements associated with such batteries and safety risks such as a short circuit or chemical/thermal reaction. Professional removability significantly increases the likelihood that batteries are correctly managed after they have been removed from equipment.

Secondary Raw Materials

Currently, the Circular Economy and the secondary raw material markets are high on the European agenda, and are attracting member state support. The digital industry has been experimenting with the use of recycled plastics in electric and electronic equipment (EEE) since the early 2000s. Where post-consumer recycled material was once considered novel, recycled plastics are now found in a variety of ICT products as companies start to use recycled plastics as part of voluntary agreements/certifications or broader green marketing initiatives.

The imaging equipment industry, for example, has signed a voluntary agreement (VA) in the framework of the Ecodesign Directive, which requires producers to declare the use of recycled plastics to customers since 2015. The VA was signed by 15 producers that account for more than 95% of all office and household imaging equipment sold in Europe. Declaration requirements of the use of recycled plastics are also in the ECMA 370 Eco Declaration.

At present, however, there are still a number of challenges to be overcome for recycled plastics to be more widely used. For any product, material sourcing and selection is one of the most important business decisions. For ICT products that are subject to complex legal requirements it is even more critical to ensure that all materials, including recycled plastics, meet multiple requirements for hazardous substance screening, safety and quality assessments, security of supply, economic viability, cosmetics, performance and consumer preference.

DIGITALEUROPE has developed a paper to showcase current best practices of early adopters, highlight the challenges ahead to policy-makers and inspire other sectors and producers. It contains an initial assessment of the market size and expected trends as well as opportunities and challenges in using recycled plastics. The last section of the paper gives ample room to a number of case studies from the ICT industry, ranging from printer cartridges to printers and closed-loop recycling in monitors.

The paper was preluded by a series of industry workshops and visits to recycling plants. While recyclers have made technical progress in the past few years, it is still not easy to find sufficient supply of high quality post-consumer recycled plastics that meets all the technical, economic, and aesthetic requirements. It is clear that the widespread use of recycled plastics in all ICT products remains a challenge. However, with a combination of economic incentives and technical progress, the ICT industry could make a meaningful progress. 

Click here to download the Best practices - Recycled plastics paper

For more information please contact:

Sylvie Feindt
Director
sylvie.feindt@digitaleurope.org       
Valentina Bolognesi
Senior Manager
valentina.bolognesi@digitaleurope.org