DIGITALEUROPE position on the Draft Amendment of the Correspondents’Guidelines No.1

Enabling the circular economy: Ensuring a free flow for products for repair and refurbishment

The Draft Correspondents’ Guidelines aim at clarifying under which circumstances EEE should be shipped as waste or not. These guidelines are an important element to prevent illegal shipments of E-Waste, a goal which the members of DIGITALEUROPE fully support. At the same time, the guidelines will have considerable impact on making the Circular Economy a reality.

The Correspondents’ Guidelines should focus on closing loopholes used by unscrupulous actors while at the same time allowing OEM’s to continue their legitimate and established processes. These processes are crucial to extend the effective lifetime of electronic equipment through repair and remanufacturing. Repair and remanufacturing are essential strategies of avoiding waste as well as saving natural resources and energy within a true circular economy.

In order to provide cost efficient repair and remanufacturing services, Members of DIGITALEUROPE have established central repair and remanufacturing facilities inside and outside of the EU. Next to waste collection strategies and Extended Producer Responsibility, this infrastructure is the circular economy backbone of the IT industry in Europe. They ensure reuse and increased lifetime of IT devices on the European market.

A DIGITALEUROPE survey from 2014 has shown that roughly 118,000 tons of IT equipment and spare-parts is globally shipped cross-border annually for repair and remanufacturing; roughly 28.000 tons in Europe. An estimated 70% or more of this volume is repair of non-professional products and 40% are ‘out of warranty’ repairs, resulting in millions of repairs/year that depend on cross-border movements in Europe alone..