E Waste Project
Report ‘Practicability and Enforceability of the WEEE Recast Proposal’
At the IMPEL General Assembly meeting, 3-5 June in Prague, the report on the Practicability and Enforceability of the WEEE Recast Proposal has been adopted.
Final report 
Workshop on the Practicability and Enforceability of the WEEE Recast Proposal
27 April 2009– Drawing on the work of the IMPEL Better Regulation Cluster to develop and use a checklist on the practicability and enforceability (P&E) of legislation, the TFS Cluster has been taking forward a project to examine the P&E of the Commission’s December 2008 Recast Proposal of the WEEE Directive. Initially views from IMPEL members were collected via a questionnaire and on 27 April a workshop was held at the new IMPEL offices in Brussels to discuss the findings.
This was Chaired by John Burns of the Environment Agency (England and Wales) and facilitated by Andrew Farmer (Institute for European Environmental Policy). Participants indicated support for a number of changes, such as coherence with RoHS and the new Directive on waste and greater emphasis on inspection and enforcement. However, practical concerns are raised on a number of issues such as defining ‘producer’ and determining what is WEEE so as to minimise leakage. A final report of the project will be produced soon addressing a wide range of issues in the Recast Proposal, with adoption of the report expected at the IMPEL Plenary in Prague in June.
Project descripton
Current information suggests that with increased turnover of electrical goods by consumers, few ‘bring back’ schemes yet to ensure compliance with the WEEE Directive and relatively high costs of recovery and recycling in member states compared to export for ‘recycling’ or insufficient capacity for recovery and recycling in some member state countries it is believed that compliance with the WSR is poor with illegal shipments of WEEE being exported out of Europe on a large scale.
This results in poor recovery rates, illegal disposal and potential health and environmental problems in countries of destination in the Far East and Africa. Failure to effectively and consistently regulate exports of WEEE across Europe will result in continuing gaps and loopholes in the European regulatory network that will be exploited by unscrupulous operators.
This project will require IMPEL TFS members to work together to develop a strategic threat assessment on European WEEE exports which will enable a fuller understanding of the trade to be achieved. A better understanding of the European WEEE export trade will provide the opportunity to develop a Europe wide control strategy which will identify the most effective interventions or tactical actions each member state can employ to disrupt illegal trade. This approach should bring about more effective regulation of WEEE exports with a corresponding reduction in complaints from countries of destination and a more environmentally responsible approach to dealing with WEEE in Europe (in line with the requirements of the WEEE Directive).
The project also offers the opportunity for some collaborative inspection and enforcement work to test the effectiveness of the control strategy and make adjustments to it as required. The project is related to the following themes of the IMPEL-TFS multi annual programme:
- Theme 1 – Threat Assessment
- Theme 2 – Communication
- Theme 3 – Use of national resources
- Theme 4 – Productive collaboration with enforcement partners across Europe