Memorandum by the Electronic Producers
Environmental Policy Forum
The Electronic Producers Environmental Policy
Forum (EPEPF) works to inform the Government and Parliament about
the impact of current legislation on the sustainability of electrical
products. Members of the Forum include industry leaders such as
Sony, Samsung, Hewlett Packard and Canon.
Most recently, the EPEPF has been working to
draw the attention of parliamentarians to the problems caused
by the Government's inchoate transposition of the Waste Electrical
and Electronic Equipment (WEEE) Directive.
The European Union's WEEE Directive charges
the producers and retailers of electronic and electrical equipment
with responsibility for increasing the reuse, recovery and recycling
of WEEE. In a letter to the waste disposal authorities in England
(dated 18 April 2007), Jeanne Grey, Assistant Director of WEEE
Implementation argued that:
"The aim of the WEEE Directive is to minimise
the negative environmental and health impacts of WEEE, and contribute
positively to sustainable development by maximising the separate
collection of WEEE from other forms of waste. This separate collection
is the precursor to the appropriate treatment of WEEE and subsequent
reuse, recycling and recovery of WEEE and environmentally disposal
of any residual WEEE".
However, as currently transposed in the UK,
the WEEE Directive only enforces a system of Collective Producer
Responsibility (CPR) which does not maximise the collection, reuse
or recycling of WEEE. CPR makes producers of electrical and electronic
goods responsible for a proportion of all WEEE that is equal to
the amount of product that they put on the market. Under CPR,
the cost of recovery, recycling and reuse are absorbed collectively
by all producers. CPR does not provide any single producer with
the incentive to make their products easier to recycle or reuse.
The EPEPF believes that the Government should
fully transpose article 8.2 of the original EU WEEE Directive
which would bring about Individual Producer Responsibility (IPR)
in the UK.
While CPR makes each manufacturer responsible
for a proportion of all WEEE, under IPR each manufacturer is only
responsible for the WEEE arising from their own products and therefore
creates an incentive for each producer to design their products
in such a way as to make them easier to recycle or reuse.
R J Lipset,[21]
the pioneer of producer responsibility theory has argued that:
"There is little doubt that extended producer
responsibility generates both economic and political incentives
for waste recovery and more broadly, green design".
IPR provides a competitive incentive for producers
to design their products so that they are easier and therefore
cheaper to recycle. By making them liable for any and all charges
arising from the costs of recycling or reusing only their own
products, IPR provides producers with a powerful economic incentive
to design those products in a way that makes them easier and cheaper
to recycle or reuse.
Without the transposition of article 8.2, the
incentive to encourage producers to focus on design for recycling
is absent. This jeopardises the attainment of the Directive's
objective which was to create "an economic incentive for
producers to adapt the design of their products to the prerequisites
of sound waste management". [EC: WEEE (2000)].
12 Member States have transposed Article 8.2
(including Belgium, Cyprus, Italy and Sweden) while 12 Member
States have not (including France, Spain and the UK). Four Member
States have partially transposed article 8.2 (including Germany).
While the UK Government has indicated its willingness
to implement IPR in principle, they have claimed that they cannot
transpose article 8.2 until a fully workable model is available.
Workable IPR models already exist in other countries such as Sweden,
Japan and parts of America. While an IPR system that sees producers
collecting, recycling and reusing their own products may not be
possible in the UK at this juncture, as a first step, a system
that makes producers responsible for a proportion of WEEE equal
to the electrical and electronic equipment they actually put on
the market, worked out through brand sampling from the waste stream,
would be a possible and positive first step. In conclusion, the
EPEPF believe that without IPR, the WEEE Directive is failing
in its main objective: to establish an incentive or producers
to design products for easier recycling and that the first step
is to ensure that Article 8.2 is properly transposed in the UK.
22 October 2007
21 Lifset, R J, "Take it Back: Extended Producer
Responsibility as a Form of Incentive Based Policy" Journal
of Resource Management and Technology, Vol 21, No 4, December
1993. Back
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