International Review of Waste Management Policy - Department of ...

stemming from a current lack of incentive to treat products in the most
environmentally-friendly way if it requires further processing and added expense. 447
The recent proposed revision to the EU WEEE Directive includes a change in collection
targets from 4 kg per annum per inhabitant to a 65% collection rate, calculated
according to the average amount of EEE placed on the market in the two preceding
years. This proposed target is more in line with the current Japanese system. In
addition, in order to encourage the re-use of whole appliances, it is proposed that
such re-use be included within the 65 % target. In addition, the proposed revision
presents the possibility of setting a separate collection rate for cooling and freezing
equipment in 2012.
Despite the figures presented in Table 20-2, it is estimated that only 25 % of WEEE
arisings within the EU are currently being collected and treated, with no precise data
available on what happens to the remaining 75%, termed ‘hidden flow’ in one
Greenpeace report. 448 It is considered to be likely that some portion of this ‘hidden
flow’ is being illegally exported to non-EU countries with lower treatment standards,
leading to increased risk of the release of hazardous substances to the environment,
an increase in the direct exposure of workers to hazardous substances associated
with the ‘informal’ recycling of WEEE in countries such as India and Thailand, as well
as the loss of valuable secondary raw materials.
Aside from the aforementioned problems associated with the current 4 kg collection
target in the EU, this target also makes it difficult to analyse the effectiveness of
policy variations on the resultant recycling of WEEE, because it does not determine
the amount of WEEE that is subsequently disposed of as opposed to being re-used or
recycled. In contrast, in Japan, recycling targets are set according to EEE placed on
the market, and the term ‘recycling rate’ in Japan only refers to any material that is
recovered without a negative balance (i.e. where the producer does not then have to
pay a firm to recycle the material). The fact that Japan was, for example, already
exceeding its 55 % target for the recycling of televisions in 2003 suggests that the
Japanese system may be more effective than the current EU system in encouraging
the re-use and recycling of WEEE. Similarly, as reported by Greenpeace (2008), Sony
in Japan are one of the few brands where a recycling rate of 53% has been achieved,
leaving a smaller ‘hidden flow’ than that found in the current EU system.
Notwithstanding these data limitations, it seems reasonable to assume that though
many of the original EU-15 have had little problem meeting a 4kg per inhabitant per
annum target, the proposed 65% collection target is likely to prove far more
challenging. Not only is this likely to require more comprehensive coverage by WEEE
collection and take-back systems, but the need to demonstrate this through formal
channels is likely to put pressure on Member States to reduce the export of WEEE
through informal channels. This might not imply an end to exports per se, but would
447 S. Flanagan (2008) UK recyclers should not follow German WEEE model, Recycle.co.uk: Don’t Bin
it, Recycle it, available at: http://www.recycle.co.uk/news/614000.html
448 Greenpeace (2008) Toxic Tech: Not in Our Backyard, Uncovering the Hidden Flows of e-Waste.
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