Why WEEE?

The European Commission Environment Directorate has at last published its proposals for a Directive on WEEE (waste electrical and electronic equipment) that should become law in EU Member States from 2003. Gary Griffiths, environmental & quality systems manager, RDC, and chair of the ICER (Industry Council for Electronic & Electrical Equipment Recycling) Recyclers Group, previews the EC Environment Directorate's official proposal for the WEEE Directive.

Certain components will have to be removed from WEEE prior to treatment - in effect, requiring dismantling for parts containing: printed circuit boards; mercury; batteries; toner cartridges; plastic containing brominated flame retardants; cathode ray tubes; CFC's, HCFC's and HFC's; LCDs>100cm<sup>2</sup>; gas discharge lamps; and asbestos.

Certain components will have to be removed from WEEE prior to treatment - in effect, requiring dismantling for parts containing: printed circuit boards; mercury; batteries; toner cartridges; plastic containing brominated flame retardants; cathode ray tubes; CFC's, HCFC's and HFC's; LCDs>100cm2; gas discharge lamps; and asbestos.

WEEE is currently the fastest growing element in our municipal waste stream, set to double to 12 million tons a year across Europe by 2010. The EC is concerned over WEEE primarily because of the hazardous substances it contains. Lead is used as solder and in cathode ray tubes in TVs and computer monitors; cadmium in plastic and CRT screen fluorescents; mercury in switches and some lamps; arsenic in printed circuit board assemblies; HCFCs in refrigerants. And most WEEE - over 90% according to EC estimates - is presently landfilled, incinerated or shredded without pre-treatment.

The aims of the WEEE Directive are straightforward:
  • prevention of waste from WEEE;
  • re-use and recycling of WEEE;
  • improvement in the environmental performance of all economic operators involved in the EEE life cycle.

WEEE has been defined (excluding power stations and nuclear submarines) as equipment dependent upon electric currents or electromagnetic fields using under 1,000 volts AC/1,500 volts DC. Components, sub-assemblies and consumables, which form part of any discarded product, is also included as WEEE. There are ten categories: large household appliances; small household equipment; IT & Telecom equipment; consumer (TV, audio, radio, video); lighting; tools; toys; medical; monitoring & control; and automatic dispensers.

One of the key themes underpinning the WEEE Directive is Producer Responsibility. Taxpayers have historically picked up the waste disposal burden and so the EC is now passing the buck - quite literally - to producers. If producers have to pay the full disposal costs, the EC believe they will reduce costs through better product design to make products less environmentally damaging and easier to recycle. Simply trying to pass costs to customers will not work in this competitive marketplace. And last, but not least, is the overall EU target of sustainable development.

Buy one get one free
Under the EC Precautionary Principle, the use of hazardous substances is to be discouraged. A Directive "on the restriction of certain hazardous substances in electrical and electronic equipment" has been produced by the Enterprise Directorate of the EU as a supplement to the WEEE Directive. Producers are charged by 2008 to phase out the use of substances such as lead, mercury, cadmium, and hexavalent chromium. Exemptions are allowed for technical necessity (e.g. lead in cathode ray tubes) and where safety or the environmental impact is negative (e.g. where the risk of injury from fires outweighs the environmental risk from use of fire retardants).

To avoid cross contamination and to ensure sufficient volumes of WEEE are recovered to facilitate economic recycling quantities, the EC proposes that WEEE be recovered and treated separately from other waste streams. Additionally, roles and obligations are allocated to key players - producers, governments, distributors and recyclers, plus key targets are set.

Producers are defined as product manufacturers, professional importers or own-brand resellers. Producers will have to set up systems to finance the collection, treatment and environmentally sound disposal of WEEE arising from non-private households. Five years after the start of the WEEE Directive, producers will also take on financing private household WEEE, singly or collectively with other producers. And products or their packaging must carry a crossed out wheely bin logo to indicate recycling - ignoring the fact that, as wheely bins are not extensively used throughout the EU, many people will not understand its purpose.

Member States will provide households with free return of WEEE - to be funded by producers after a five-year transitional period. This is a pragmatic recognition of the use of the existing government waste management infrastructure as a foundation for the producer systems to follow. Governments will provide users with information about return and collection systems and will also licence all WEEE recycling and waste management organisations in line with current licensing regulations. Data gathering and standards for WEEE re-use and recycling will also be developed by Governments.

Take products back free
Distributors - anyone who provides electrical or electronic products on a commercial basis to the user of that product - will be obliged to take such products back free of charge from private households when supplying new products. Such 'take-back' WEEE will then be delivered to authorised collection facilities for recycling. An exemption is granted for products suffering radiological or biological contamination (such as certain cookers and refrigerators with pathogenic contaminants such as e-coli and salmonella).

Recyclers have to hold the necessary permits and authorisations to operate treatment facilities to process WEEE. Recyclers processing facilities must have a balance (weighing equipment), appropriate storage for disassembled parts and appropriate containers for hazardous waste. Facilities must also treat water used in processing and surface run-off.

The EC has calculated the overall costs of implementing WEEE as adding between 1-3% to the costs of electrical and electronic products, dependent upon the degree of difficulty in collection and recycling. Electronic selling - internet trading - is also included as falling under Producer Responsibility, although how this is to be enforced is not discussed.

Supply chain impact
The WEEE Directive will impact upon the electrical and electronic products supply chain. To meet the requirements of this new Directive, the supply chain will need to be extended to include recovery from consumers, recycling and waste management. Clear supply chain audit trails of the purchase, use and disposal of products will be needed to monitor the value recovery and to limit the liability for the costs of disposal and recycling at the end of products' life.

Used IT equipment can be refurbished and reused or sold. Unwanted or faulty equipment can be dismantled to recover components for resale, before the metals, glass and plastic can be recycled. Monitors, however, are harder to deal with. Lead and phosphors in the cathode ray tube are hazardous, and fire retardants in plastic casings make them difficult and costly to recycle. There is no-one in the UK currently recycling monitors or TVs to the requirements of the WEEE Directive.

And even though the option of reselling IT equipment is attractive, there are potential risks involved, such as the disclosure to the new user of confidential data left in the memory, the new user injuring themselves from faulty electrical connections, and the unauthorised transfer of licensed software. Poor-quality second-hand goods may also taint brand image and a company's reputation. Such issues are not covered in the WEEE Directive, but have been tackled by ICER (the Industry Council for Electronic & Electrical Equipment Recycling) who have produced a Code of Practice for IT Equipment Refurbishment now adopted by the Department for Education and Employment. ICER also has an accreditation scheme for electrical and electronic equipment recyclers.

Stream of WEEE
There are some concerns that continue to plague the WEEE Directive. How electronic trading is to be controlled is unclear. There remains a risk that WEEE will be dumped outside the EU for processing in countries with poorer regulation and lesser standards. And by setting recovery and recycling targets against a rapidly growing waste stream, extrapolation shows that, for example, 75% of IT recovered and 65% re-used or recycled leaves 51% of WEEE either not recovered or not recycled. Given that the amount of WEEE is set to double by 2010, this means that the amount now being disposed of to landfill and incineration may well stay the same. The Directive will now go before the Members of the European Parliament for discussion and possible amendment before being officially adopted - probably within 15 months. Member States have up to 18 months to adopt thereafter - hence the majority of targets set for January 2006. Which means producers, distributors, recyclers and governments need to start planning now.



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