It is frustrating to see our old electronics being trashed, including at local recycling centres, especially when we know they could have been used by someone else. Waste policies favouring recycling over re-use, including the lack of separate EU targets for preparing for re-use, have led to a situation where waste collection and logistics systems tend to be unsuitable for supporting re-use activities.
A European standard for the collection and logistics of waste electronics is currently being finalised, in the form of a so-called ‘Technical Specification’. This technical specification is expected to be voted upon by the members of CENELEC, the National Electrotechnical Committees, on 17 February 2017.
This document is meant to help implement the WEEE Directive, in particular to ensure that collection and transport of WEEE is done under ‘optimal conditions for preparing for re-use, recycling, and confinement of hazardous substances’. Handling electronics with care will keep them going for longer.
While we do not oppose the adoption of this technical specification, we see a need for an early revision of the specification as soon as it is adopted to address major shortcomings that we feel insufficiently support preparing for re-use activities, nor quality recycling to some extent. The specification also contains provisions which are less stringent than what some Member State legislation currently requires.
In particular, the early revision of the draft specification should focus on:
- Ensuring that WEEE separated for preparing for re-use is done at the earliest stage possible in the collection and logistics chain.
- Providing greater clarity concerning identification, handling and storage of potentially re-useable appliances versus those which are destined to be recycled. The current wording of the standard gives too much room for interpretation which could allow for storage of equipment intended for re-use, such as large household appliances without weatherproof facilities.
- Assuring stronger wording to secure partnerships between collection and logistics operators with those operators who prepare waste electronics for re-use. Such partnerships would help facilitate much needed access to re-useable goods prior to them being directly recycled, buried or burned.
In the meantime, we would encourage the European Commission to scrutinise over the final text to determine if it sufficiently aligns with the WEEE Directive.
Our recommendations for the early revision of this technical specification include the need:
- To ensure a more balanced representation of all stakeholders in the standardisation process so that it can be reflected in the final text. Standards can be a supportive tool for preparing for re-use operators to further develop their activities and support local job creation. This however requires to ensure that the re-use sector is greatly involved in the standard development process, which hasn’t been the case so far as they were in minority despite the potential impact such standards can have on their operations.
- For standardisation organisations to take concrete steps to make the standardisation process more accessible to underrepresented stakeholders, such as civil society organisations and SMEs, including at national level. Existing obstacles ought to be removed, such as participation fees where applicable.
- For draft standards responding to a European Commission’ Standardisation Request to be made available for full public consultation, and freely available online once published, so that all stakeholders are aware of them and their possible impacts, and can contribute most effectively.
- For a regular overseeing from the European Commission over the standards development process when linked to a Standardisation Request, to help ensure balanced representation where necessary and coherence with policy goals.