Memorandum to Czech Presidency and Ten Test - EEB

EEB Memorandum to the Czech EU Presidencyimposing a flat and undifferentiated fee to all producers, which would createserious barriers to the implementation of individual producer responsibility.Requiring producers to be fully financially responsible for the collection ofWEEE from households. Producers should pay for full collection costs andnot only the costs of collection from points of deposition onwards. In order toprevent abuses, this should be complemented with mechanisms forproducers to question and control abuses of costs.- Clearly re-establishing the objectives to prevent, reuse and recycle WEEEin Article 1 and ensuring that improvements on Ecodesign focus on reuseand recycling and not “recovery” as proposed in the new article 4.Stronger drivers for reuse should also be introduced through dedicatedreuse targets.7.10. RoHS RecastWidespread contamination by hazardous substances and materials used inelectrical and electronic equipment is still a matter of high concern due to thelimited scope of the restriction of the use of certain hazardous substances inelectrical and electronic equipment (RoHS) legislation. Not only are manyundesirable substances and materials still used in products but other harmfulsubstances, such as dioxins and furans, are generated in these products duringrecycling and disposal at end of life, much of which still takes place in backyardworkshops in developing countries. These hazardous substances have beenrecognised as priority contaminants in the Stockholm Convention, which seeks toeliminate persistent organic pollutants from the global environment.Together with the WEEE Proposal, the Commission published a proposal for arecast of the Directive on RoHS on 3 rd December 2008.We expect the Czech Presidency to make a positive contribution to improving theproposal, which is crucially needed. No new substances were proposed forbanning in the new proposal and it is suggested that the assessment ofsubstances to be restricted would be undertaken under a modified procedureaccording to REACH, which would be further defined by the Commission.The REACH Authorisation process is still in its early development stages and it ishighly uncertain if and how REACH will address chemicals relevant to theelectronics sector. REACH also fails to address all the life-cycle impacts ofchemicals, especially related to end of life. On the other hand, RoHS provides aclear timeline for signalling when newly identified hazardous chemicals need tobe replaced by safer alternatives. Electronics companies today have introduced aframework to comply with RoHS. Accordingly, the companies affected by RoHS37