Joint Letter on Proposed Unitary Own Resource on Non-Collected E-Waste

The Electrical and Electronic Equipment (EEE) producer industry stands firmly alongside the EU in working to achieve ambitious climate and environmental protection goals, significantly contributing to saving energy, resources and greenhouse gas emissions. While we support the EU’s efforts to establish a suitable legislative framework for environmental and climate protection, we are writing to you today to express our profound concern regarding the proposed unitary own resource of €2/kg on non-collected e-waste within the Multiannual Financial Framework (MFF), the EU’s long-term budget. This planned initiative is an inadequate answer to the e-waste collection objectives of the EU and requires urgent correction to effectively promote environmental protection.

We believe this measure is ill-conceived and risks creating significant market fragmentation, excessive financial and administrative burden, while unsupported by robust, harmonised data. Solid indisputable data is a basic legal requirement for any financial levy. Taken together, these shortcomings risk significantly weakening the sector’s competitiveness, a critical element for a thriving European circular economy. We urge policymakers to reconsider this approach and suggest that a more constructive and effective path lies in adapting the existing regulatory framework.

The current rules governing e-waste in the EU are set out in the Waste of Electrical and Electronic Equipment (WEEE) Directive. This legislation places responsibility on producers to finance the collection, treatment and environmentally sound disposal of e-waste. It also sets national collection targets and recycling/recovery requirements across Member States.

While the Directive created a solid foundation, it has clear limitations: collection targets are not being met, enforcement is uneven, and many actors involved in e-waste handling are not properly regulated or held accountable. The European Commission plans to revise the WEEE Directive as part of the Circular Economy Act, expected in late 2026. This is a real opportunity to strengthen the system and boost both collection volumes and recycling quality.

Discover our joint recommendations in the letter below.