Memorandum submitted by the UK Cartridge
Recyclers Association (UKCRA) (E19)
I am writing in respect of the inquiry the Environment
Committee is holding into the WEEE Directive. As you may be aware,
there has been widespread concern amongst recyclers, in particular
the remanufacturing sector; charities and environmental NGOs that
printer cartridges are being excluded from the directive by the
UK Government. I very much hope, therefore, that the committee
will address the limited scope of the UK's interpretation of the
Directive, inquiring why printer cartridges (toner and inkjet
cartridges) are being excluded when there are significant benefits
to business, the environment and good causes to be derived by
their inclusion.
The exclusion of cartridges has become an issue
about which a number of MPs, across all parties, have become concerned.
Indeed, aside from EDM no 1319, there has been a plethora of parliamentary
questions tabled which have received wholly unsatisfactory responses
from the Government.
For your information, I am attaching a short
briefing note [not printed] on these issues. However, the basis
of our arguments can be summarised as:
— Printer cartridges meet the definition
of electrical/electronic equipment contained in the directive
and recently agreed by the EU technical adaptation committee (see
DTI website).
— The Government claims that cartridges
are consumables (we contest this) but nowhere does the Directive
state that consumables are excluded.
— If the UK Government wants to exclude
all consumables, it can do so without excluding cartridges as
a specially defined consumable—the Directive allows for
gold plating.
— There is no doubt that MEPs believed
printer cartridges to fall within the scope of the Directive,
when they voted by an exceptional majority for the inclusion of
what was to become Article 4 of the Directive.
6 November 2003
|
