European Recycling Platform (ERP) has contributed to the European Commission’s public consultation on its proposal to amend the Waste Electrical and Electronic Equipment (WEEE) Directive.
European Recycling Platform (ERP) has contributed to the European Commission’s public consultation on its proposal to amend the Waste Electrical and Electronic Equipment (WEEE) Directive. The review addresses the question when and by whom the takeback of PV modules must be financed and was triggered by a ruling of the European Court of Justice (see article in March’s COMPASS).
In its position paper, ERP used the opportunity to address additional aspects on collection and financing. Regarding collection, ERP proposes to introduce a separate category for PV modules and to strictly separate this from the current category of “large equipment” as both types of equipment have fundamentally different characteristics and lifetimes.
Each sector should be able to achieve the collection targets with its own products, rather than being forced to achieve them by collecting other products, jeopardising the achievement of the collection target in another product sector.
ERP also advocates an adjustment of the current collection target of 65%, which is unrealistic given the long lifetime of PV modules. The target should therefore be calculated based on the volume of waste modules available for collection rather than the volume of new modules placed on the market.
In addition, due to the long lifetime of the modules, and to create a level playing field between producers and producer responsibility organisations, specific measures need to be implemented to ensure a sufficient and secure budget for future waste obligations.
The next step will be for the European Parliament and Member States to consider the Commission’s proposals.