DIGITALEUROPE Position on Differentiated EPR Costs

As stated in our position paper of 8 February 2016, DIGITALEUROPE supports the Commission’s initiative to address the challenges of moving to a Circular Economy.

Recycling fees should reflect real end of life costs of electronics recycling.
Under EPR manufacturers should receive economic incentives to improve their product design to facilitate easy treatment and recycling. In particular, we welcome any reduction in costs relating to the end-of-life treatment that can help make secondary raw materials more competitive. Such an approach should be harmonised between Member States to provide consistent incentives and rewards to manufacturers. Overall, differentiated recycling costs should be used as a tool to cover end of life costs of products and compensate for the efforts of manufacturers addressing the End of Life (EoL) aspects of their products, but not to incentivise broader aspects of environmental performance of EEE.

In order to ensure an effective approach, it is essential that the following requirements are met:

1. It is important that harmonized criteria are established and applied consistently across the EU.

2. Reporting requirements for equipment should not be more complex than current requirements. In addition, differentiation of recycling costs should not create new administrative requirements (for example to visibly display fees on invoices or at point of sale). Additional administrative burdens are contrary to efforts to increase the competiveness of the EU and will act as a disincentive for differentiation of recycling costs.

3. It is important that criteria underlying recycling cost differentiations are consistent with internationally recognized environmental product labels and certification schemes, both in technical content and required documentation. All criteria must be based on a transparent process and robust data. Impact assessments need to be good practice for the establishment of such criteria.

4. Producer’s financial contributions should be based on the real costs of treatment. This would provide incentives for greater recyclability. Currently recycling costs are not accurately reflected in producer fees in all schemes. For example, some of the criteria set forth in the French ‘modulated fees’ system are unrelated to recycling costs. To this extent, the French model falls short of being a role model for European harmonisation.