WEEE, WEEE, WEEE, WEEE, all the way home? An evaluation of proposed electrical and electronic waste...

European EnvironmentEur. Env. 10, 121–130 (2000)

WEEE, WEEE, WEEE, WEEE, ALLTHE WAY HOME?AN EVALUATION OFPROPOSED ELECTRICAL ANDELECTRONIC WASTELEGISLATION

Tim Cooper*

Sheffield Hallam University, UK

Over the past decade the EuropeanCommission has been developing plansto address environmental problemscaused by a growing volume of wastefrom electrical and electronic products. Ithas recently published a series ofproposals for a draft Directive. Using arecognized analytical framework, thispaper evaluates arguments for andagainst these proposals in the light ofresponses from stakeholder interestgroups. It assesses the strong criticismsvoiced by some industry representativesand the reservations of environmentaland consumer organizations. The paperconcludes that the proposed legislation,if refined and implemented effectively,would represent a highly significantadvance in environmental policy, aswaste-related environmental costs wouldbe internalized into the price of electricaland electronic products. Sustainableproduct design could thereby bepromoted. Copyright © 2000 John Wiley& Sons, Ltd and ERP Environment.

INTRODUCTION

Waste generated from the disposal ofhousehold appliances has attractedconsiderable interest from European

Commission policy analysts over the pastdecade. Millions of these electrical and elec-tronic products are discarded in Europe eachyear. The volume of this waste streamamounts to around 6 million tonnes per an-num in the European Union, equivalent toeach household generating, on average, 25–30kg per year (AEA Technology, 1997). Wasteelectrical and electronic equipment (WEEE) isexpected by the European Commission to in-crease by 3–5% per annum, thus doublingwithin 12 years. Many of the discarded prod-ucts contain toxic substances such as lead,mercury, hexavalent chromium, cadmiumand halogenated flame retardants.

In response, the Commission has draftedlegislation to address these environmentalproblems. The proposed ‘WEEE Directive’aims to prevent waste, to promote re-use,recycling and other forms of recovery and tominimize environmental risks and impacts as-sociated with the treatment and disposal ofdiscarded equipment.

This paper uses a simple analytical frame-work based on the three domains of environ-mental, economic and social sustainability toevaluate the current proposals. It identi-fies and assesses the responses of influential

* Correspondence to: Tim Cooper, Centre for Sustainable Con-sumption, School of Leisure and Food Management, SheffieldHallam University, Pond Street, Sheffield S1 1WB, UK.

Copyright © 2000 John Wiley & Sons, Ltd and ERP Environment.

T. COOPER

stakeholder interest groups, and seeks to ex-plain the strength of criticism voiced by someindustry representatives. Finally, it drawsconclusions on whether the proposal repre-sents a significant advance in environmentalpolicy and is likely to be effective in practice.It has been prepared as part of a programmeof research at Sheffield Hallam University onthe environmental impact of householdappliances.

THE EU PROPOSALS

Origins

The origin of this policy initiative can betraced to the decision by the European Com-mission in 1991 to designate a series of ‘prior-ity waste streams’ it believed were in need ofparticular attention, among which was wastefrom electrical and electronic equipment. Aproject group on WEEE was established bythe Commission in order to produce a strate-gic framework within which to make recom-mendations. However the group had severedifficulty in reaching a consensus view duringthe 18-month period available and this wasevident when its report was published in 1995with a wide range of unresolved issues (ECProject Group on Waste from EEE, 1995).

Meanwhile several EU member states, nota-bly the Netherlands, Germany and Sweden,were developing national policy measures todeal with the electrical and electronic prod-ucts waste stream. Experts warned that theEU needed to initiate its own policy in orderto harmonize industry requirements acrossmember states (Welker and Geradin, 1996). Iflegislation was introduced in some memberstates but not others, as appeared increasinglylikely, there would be serious implications forthe operation of the single market.

During 1996 and 1997, the Council and Eu-ropean Parliament passed resolutions that re-quired a follow-up to the priority wastestreams programme. A further report wascommissioned in order to increase the dataand information available and identify possi-ble options for improving the management of

WEEE. This proved a rather more coherentstudy, although it, too, highlighted severalpotential problems (AEA Technology, 1997).Despite these outstanding concerns, a draftproposal for a Directive was published inApril 1998, followed by a revised draft threemonths later and a third draft in July 1999.

Key measures

The key elements of the proposed legislationmay be summarized as follows. Memberstates are to be required to ensure that collec-tion systems are set up to enable discardedWEEE to be returned by private households,other organizations that normally use the mu-nicipal waste stream and distributors (i.e. re-tailers, including rental companies). Thecollection service is to be free to privatehouseholds, and when distributors supplynew products to consumers they must allow‘similar’ equipment to be returned free ofcharge. The collection facilities in these ‘takeback’ systems must be readily accessible tothe public, although population density istaken into account.

Producers (i.e. manufacturers and im-porters) are required to establish systems toprovide for treatment and recovery (e.g. re-use, recycling or energy from waste). More-over, they are to bear the cost of collection,treatment, recovery and environmentallysound disposal of WEEE from privatehouseholds.

Disaggregated data on waste generated inthe EU is currently poor and member statesare required to submit data on ‘achieved ratesof collection’ from private households by 1January 2004. They must also ensure that pro-ducers submit information on new productsput on the market by the same date. It isintended that the Council and Parliamentwill, in due course, establish ‘compulsorytargets’ for collection from 1 January 2006.

Member states must set up systems toensure that producers meet minimum re-quirements for the recovery of certain cate-gories of discarded equipment. The require-ments for 1 January 2004 have been set at 90%for large household appliances and 70% forsmall household appliances, equipment with

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cathode rays (e.g. computer monitors andtelevisions), toys and electrical and electronictools. They are to be reviewed before 2006.The recovery requirements currently pro-posed are, of course, based on unknown col-lection totals. However it is anticipated that,overall, a minimum of 4 kg of WEEE perinhabitant will be collected each year fromprivate households.

Member states are also to promote the de-sign and production of equipment that facil-itates repair, upgrading, re-use, disassemblyand recycling and to encourage producers toincrease their use of recycled and recyclablematerial. The collection and transport ofWEEE is to be undertaken in such a waythat components and whole appliances maysubsequently be re-used or recycled. Simi-larly, treatment prior to recovery or landfill-ing, which is required, should allow forsubsequent re-use or recycling, and all estab-lishments undertaking treatment must becertified.

The use of dangerous substances is to berestricted. Member states are to ensure that,with certain exceptions, the use of lead, mer-cury, cadmium, hexavalent chromium andcertain brominated flame retardants (PBBsand PBDEs) is phased out by 1 January2004. They are also to encourage producersto minimize the use of such substances.

Finally, treatment facilities must be pro-vided with the information necessary toidentify components and materials, andhouseholds must be supplied with informa-tion about their role and the available collec-tion systems.

A FRAMEWORK FOR POLICYANALYSIS

In any analysis of proposed legislation anappropriate framework for studying the pol-icy is necessary, the choice of policy instru-ment needs to be assessed, and the policydetail must be subjected to appraisal (De-partment of the Environment, 1991). Policyanalysis is a complex process, which in-volves a systematic investigation based on

information gathered for and against eachoption (see e.g. Carley, 1983). A simple ana-lytical model is used in this paper, which isbased on the three domains of environmen-tal, economic and social sustainability (e.g.McLaren et al., 1998; see Table 1, below).

The environmental sustainability criterionrequires that the policy should achieve theintended outcome of reducing the environ-mental impact of consumption and thus con-tribute to sustainable development. Evidenceis needed that environmental benefits arelikely to result from the measure that willexceed any negative impacts that also arise.The fact that environmental impacts may notbe readily quantifiable can make this task ofmeasuring costs and benefits difficult. Itmay also be necessary to form a judgementon the relative importance of different im-pacts (e.g. air emissions and waste volumes).Use of the precautionary principle is as-sumed.

As noted above, one purpose of policyanalysis is to determine whether the pro-posed approach is the one most likely toachieve the stated objectives. Research inwaste prevention and management does nothave a strong academic tradition in the so-cial sciences, with, perhaps, the exception ofrecycling. Even so, several different method-ological approaches are available. The studyof disposition behaviour is particularly rele-vant (see e.g. Jacoby et al., 1977; Hanson,1980; Harrell and McConocha, 1992), as isthe behaviour of companies in end-of-lifeproduct management (Gertsakis et al., 1998;Kostecki, 1998). Another approach, associ-ated with industrial ecology, is to focus onthe impact of policy measures on the flowof materials and energy in the economy(Ayres, 1996; Jackson, 1996).

Table 1. Analytical framework


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Economic sustainability, defined here aseconomic progress compatible with sustain-able development (as distinct from economicpolicy stability), is the second element in theframework. Policy must contribute to the de-velopment of a more sustainable economy if itis to be effective. The basis for much environ-mental legislation is the need to correct mar-ket failure when individuals or companiesavoid paying the full costs associated withconsumption because these are ‘externalized’and paid by society as a whole. For example,the cost of health care required because ofpollution caused by the manufacture or use ofproducts is (in general) paid collectivelythrough taxation. Similarly, the cost of house-hold waste collection and disposal is currentlypaid by local taxpayers regardless of theiroutput of waste. One important criterion forassessing policy is thus the extent to whichthis kind of ‘market failure’ is corrected andexternality effects reduced.

In addition, an evaluation is required of thelikely economic cost of achieving the antici-pated environmental benefits, the test of pro-portionality. This should be undertaken at anaggregate level in order to assess the macro-economic implications of the legislation, suchas the cost to industry or the effect on em-ployment. It is also needed at a more detailedlevel, broken down by each element of policyor product category, in order to ascertainwhether the economic cost of each differentpart of the legislation is reasonable.

A third criterion is the social sustainabilityof policy or, more specifically, distributionalequity. Environmental measures will notprove sustainable if they are implemented atthe expense of social cohesion. Although therewill inevitably be conflicts of interest whenoptions exist for either public sector or privatesector activity (as, for example, with wastecollection), an effective policy will minimizeperceived injustice and secure compliance.

One means of addressing the likely socialimpact of policy is to explore the equity con-cerns of stakeholders such as producers, re-tailers and consumers. If stakeholders aresatisfied, pro-active support and complianceare more likely, resulting in effective imple-mentation. Such support is particularly im-

portant when legislation is based on marketinstruments designed to offer flexibility andpromote active industry engagement.

The acceptability of policy to differentstakeholder groups will be influenced by theirsense of responsibility for the problem beingaddressed. This is an issue of considerablecontroversy in the context of waste. In Eu-ropean Union countries there is a trend to-wards applying the concept of ‘producerresponsibility’, which is intended ‘to ensurethat industry assumes an increased share ofthe responsibility for the wastes arising fromits products’ (Department of the Environment,1995, p 13) based on the ‘polluter pays’ princi-ple. Strongly advocated by environmental or-ganizations, its proponents believe that it‘generates powerful incentives for changingthe environmental attributes of products’ (Lif-set, 1993, p 164). Its initial application can betraced back to German policy on packagingwaste at the start of the 1990s. An alternativeapproach more often supported by industryrepresentatives is that of ‘shared responsibil-ity’, which places responsibility upon allstakeholders (see e.g. FEI, 1999). Analysis ofsocial sustainability in the context of thesecontrasting approaches needs to embrace bothethical and practical considerations, and ideo-logical assumptions about individual and col-lective roles in society should be understoodand, ideally, made explicit.

It should not be assumed from the outsetthat policy intervention is valid. The value ofusing legislation as a tool for change, as dis-tinct from a voluntary approach, needs to beassessed. In the United States, for example,voluntary approaches to WEEE have beenstrongly advocated (see e.g. Cotsworth, 1999).Public policy can have far reaching implica-tions and carefully considered boundariesneed to be drawn. For example, in the contextof the proposed WEEE Directive there is notonly an assumption that governments canplay an effective role in the management ofwaste, but also that they are entitled to influ-ence the type of products people consume.Finally, the appropriate level at which to ap-ply legislation must be considered, taking ac-count of subsidiarity and single marketimplications.


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ASSESSING THE PROPOSEDLEGISLATION

Stakeholder responses

The proposed WEEE Directive has been sub-ject to very limited discussion in specialistand academic journals and negligible cover-age in the national media. The assessment inthis paper is based on evidence from twoseminars held in Spring 1999, subsequentdiscussion with several key participants andposition papers produced by the main stake-holder interest groups. It also draws on thefindings of a series of focus groups con-vened by ICER (the Industry Council forElectronic Equipment Recycling), an influen-tial UK organization in the debate (ICER,1998). One of the seminars was organizedby Euroforum, held in London and attendedmainly by representatives of industry, whilethe second was organized by ANPED (TheNorthern Alliance for Sustainability), held inSoesterberg, the Netherlands, and attendedmainly by non-governmental organizations.

The proposals have been subject to wide-spread criticism by industry representatives,but have been welcomed with only a fewreservations by environmental and consumerorganizations. The initial drafts have beensignificantly amended and the latest pro-posals appear rather less onerous to indus-try. Earlier versions included collectiontargets and had recovery requirements thatcovered more product categories and were,in some cases, higher. They also proposedthat all halogenated flame retardants shouldbe banned, and that plastics in new prod-ucts should have a minimum 5% recycledcontent.

Most industry representatives accept thatsome kind of regulation on waste electricaland electronic equipment is an inevitableconsequence of the need for policy harmo-nization in the single market. However,while they support the stated objectives,many do not support the prescribed ap-proach. They object in particular to beingexpected to take responsibility for waste col-lection, and to the requirement to phase out

dangerous substances (e.g. FEI, 1999; Orgal-ime, 1999).

Industry representatives have made othercriticisms, which are discussed below, but atthis point it is worth seeking to explain thestrength of opposition. The most obviousreason is that the companies affected fear aloss of profitability if their costs increase,prices rise and consumer spending patternsconsequently change. A second is thatwithin much of industry there is an instinc-tive dislike of legislation as opposed to vol-untary action. Thirdly, and more directly inrelation to waste, many manufacturers dis-agree with the producer responsibility prin-ciple, pointing to their dependence onconsumer responses and the influence of re-tailers. A fourth explanation lies in the factthat many know relatively little about whathappens to their products after they aresold, and maintaining a degree of responsi-bility for them throughout the product lifecycle represents a major challenge to theirorganizational culture. Finally, there is awidely held belief that regulators do not ap-preciate the economic costs involved in com-plying with environmental legislation.

Environmental and consumer organiza-tions, while generally supportive of the pro-posed Directive, want some aspects to bestrengthened (BEUC, 1999; EEB, 1999). Theybelieve that it does not give enough empha-sis to waste prevention and re-use, and ar-gue that the recovery requirements shouldbe progressively strengthened and that addi-tional dangerous substances should bebanned.

An analysis of key criticisms

The European Commission’s proposals havethus been subjected to a variety of criti-cisms. The remainder of this section presentsa summary of the main concerns expressed(Table 2) and analyses them within theframework of environmental, economic andsocial sustainability described above. In thefinal section conclusions are drawn andsome recommendations made.


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Table 2. Areas of controversy in the proposed WEEE Directive

EnvironmentalScope Is the scope of products covered by the legislation, which includes small appliances,

too broad?Targets Do the minimum recovery requirements have a proper basis? Are they too demanding,

or do they need to be broadened to include more product categories and progressivelyincreased?

Dangerous substances Is the scientific evidence for banning substances convincing? Might the substitutesprove equally damaging? Should a wider range of dangerous substances be banned?

Material and energy flows Has enough emphasis been put on waste prevention and re-use? Will the feedbackeffect on new product development created by producer responsibility be adequate?How great will be the environmental impact of transport arising from the collectionand recovery infrastructure?

EconomicCommercial impact Will manufacturers’ costs rise substantially, causing them to become less competitive?

Are the overall costs involved proportionate to the environmental benefits?Competition Will different national practices in implementing the legislation create trade barriers

within the European Union? Will companies trading from outside the EU be unfairlydisadvantaged?

SocialIs producer responsibility for waste collection justified? Should local authorities con-Equitytinue to play a major role? Do retailers face unrealistic responsibilities?

Stakeholder acceptability Will all stakeholders respond positively to the legislation once enacted?

The proposed measures have the potential tocontribute substantially to environmental sus-tainability, reversing the upward trend inwaste creation and improving waste manage-ment. The range of possible benefits includesreduced landfill, raw material extraction, en-ergy use and toxic emissions and residues.Although transport impacts from the collectionand recovery infrastructure could increase, theenergy costs involved would be insignificantcompared with the savings to be achieved fromrecycling (AEA Technology, 1997). Quantifyingall of the environmental and health impacts is,however, difficult. Some potential benefits maybe readily estimated, such as those resultingfrom the use of recycled rather than virginmaterial. Others, such as the reduced risk fromdangerous substances, are less easily quanti-fied.

The scale of the environmental benefits willbe affected by the disposition behaviour ofconsumers. Consumers need to be motivated torespond appropriately. For example, theymight choose to ignore the information produc-ers will be required to provide and discardtheir small appliances with other householdwaste. Equally, a crucial factor in determiningthe environmental benefits will be the extent to

which industry responds to the new demandsof end-of-life product management by adopt-ing the principles of sustainable product designin new product development. Thus the poten-tial environmental benefits of the legislation areconsiderable but the outcome will depend onthe influence of many external factors.

The second part of the analytical frameworkrelates to the economic implications of thelegislation. The correction of market failure inthe form of environmental externalities is oneof the key requirements of sustainable develop-ment. The transfer of financial responsibilityfrom taxpayers (whose contributions to wasteproblems vary) to consumers (whose pur-chases ultimately create the waste) representsan important advance in environmental policy.The attempt to use the market to create a designfeedback mechanism, though, is not whollyconvincing. Ideally the market should rewardproducers who take a lead in sustainableproduct design. Unfortunately, however, thefinancial arrangements underpinning the sys-tem will not necessarily encourage ‘direct pro-ducer responsibility’ (i.e. producers takingresponsibility for their own brands rather thansharing costs). Indeed there is a specific mea-sure to prevent discrimination against pooled


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collection and recovery systems, even thoughthese are less likely to result in brand separa-tion and appropriate companies being re-warded for environmentally sensitive design.

The extent to which the economic cost ofthe legislation will prove proportionate to theenvironmental benefits is hard to judge be-cause the compliance costs faced by industryare strongly contested and the environmentalbenefits hard to quantify. On the basis of aseries of pilot projects the Commission calcu-lated that the cost of collection and recyclingshould amount to no more than €900m forall EU member states, implying price rises ofno more than 3% (European Commission,1999). By contrast, industry representativeshave produced a far higher estimate of£2500m for the UK alone (ENDS, 1998) andwarned of prices rising by up to 8% (Mull-ner, 1999). Both sets of figures excluded thecost of phasing out dangerous substancesand redesigning products. More research isneeded in order to draw firm conclusions onthis specific issue.

In analysing the proposed legislation in re-lation to the third domain, social sustainabil-ity, it is necessary to consider differentopinions concerning with whom responsibil-ity for waste rests. It has been argued con-vincingly that producers should take primaryresponsibility for the management of WEEEon the basis that it is they who largely deter-mine the waste management implications ofused products (Mayers and France, 1999).Moreover they will normally be able to passon the costs to consumers. This neatly en-shrines an ethical and practical justification.More controversially, it might be suggestedthat, as suppliers, the producers’ responsibil-ity for collecting waste from consumers isgreater than that of municipal authorities,even though it may be practical for this taskto be subcontracted to the latter. At the sametime, it would be unfair if producers whorespond to the legislation by setting up ap-propriate collection, treatment and recoverysystems and designing products that causeless waste suffer any commercial disadvan-tage. There must be equity within stake-holder groups as well as between stake-holders.

Any policy designed to have a substantialeffect on the distribution of costs in society isbound to attract controversy. Some produc-ers are concerned that market conditions intheir sector will prevent them from beingable to pass on increased costs to consumers,who also bear a degree of responsibility.Whatever the extent to which such concernproves valid, the important point in thepresent context is that many producers per-ceive the proposals as lacking distributionalequity. This problem may not be easily re-solved, however, at least until more isknown about the infrastructure costs and po-tential role of municipal authorities.

Consumers in general do not appear to befacing any major equity concerns. Althoughpeople in lower income groups are more vul-nerable to increased prices, there is no inde-pendent evidence that prices will risesubstantially. Indeed the legislation shouldoffer an advantage to poorer consumers whonormally cannot afford to purchase productsdesigned for a lower environmental impact,as these should become relatively moreaffordable.

The final element in the analysis concernsthe validity of policy intervention. There ap-pears a general consensus among memberstates that instituting a policy on WEEE isappropriate. It is also accepted that EuropeanUnion environmental policy should incorpo-rate waste management within the widercontext of an integrated product policy(SPRU–Ernst and Young, 1998). This isnot to deny the need for complementarydemand-side measures to address over-consumption.

The proposals are more controversial interms of the appropriate level of government.At a global level, the case made by UnitedStates interests that they are trade restrictivewill quite properly be strongly contested bythe Commission. A more reasonable concernis the uncertain role of municipal authoritiesin future waste collection. The flexibility inthe current proposals threatens the aim ofharmonized trading conditions within thesingle market, as it allows for the possibilitythat collection costs will not be internalizedin the price of products in all member states.


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CONCLUSIONS,RECOMMENDATIONS ANDPROSPECTS

The WEEE Directive could represent a highlysignificant advance in environmental policy,although current proposals need to be refinedand the legislation must be implemented ef-fectively. The foregoing analysis suggests thatthere are several uncertainties, partly becauseof flexibility introduced in order to make theproposed legislation more widely acceptable.Some of these could be readily overcomethrough further research, while others may beclarified as producers develop their practicalresponses to the legislation. This need notmatter. Policy specialists such as Lindblomcriticize attempts to be highly prescriptive atthe outset and argue that incrementalist deci-sion making is preferable as it results in abetter outcome (cited by Hill, 1997).

The current proposals should be refined intwo ways: they need to be strengthened inorder to increase the pressure for movementup the waste management hierarchy (i.e. pre-vention, re-use, recycling, energy recovery,landfill), and there needs to be improved clar-ity of intent in order to avoid loopholes. Theseare considered in turn.

First, additional incentives are needed inthe legislation to promote waste prevention,such as a requirement for member states topublish waste prevention plans and to en-courage longer lasting household appliances(Cooper, 1996). The proposals focus on recy-cling rather than increasing the life span ofproducts, which would prevent waste and is

an essential element of sustainable productdesign. Consumers need information on thedesign life of products in order to identifythose likely to cause less waste, not merelyinformation on waste collection and wasterecovery (Cooper, 1994). There is in addition astrong case for restoring some of the stricterminimum requirements for recovery thatwere in earlier drafts. Evidence from Ger-many has suggested that ‘if you set industrytough challenges and targets, industry willrespond with new inventions and new tech-nology and generally greater efficiency’(Voute, 1995, p 66). Recovery requirementsshould differentiate between recycling in or-der to encourage refurbishment wheneverappropriate, as proposed by re-use and recy-cling companies operating in the social econ-omy (CREATE UK et al., 2000).

Second, there remain several significant ele-ments in the proposed legislation that needclarification. They include the exclusion ofany explicit reference to historic waste, theless stringent financial arrangements for cer-tain product categories, unresolved waste col-lection issues involving producers andmunicipal authorities, an unclear mechanismto reward producers who make the most ef-fort to reduce the waste impact of theirbrands and the different treatment of privatehouseholds and organizations as ‘last holders’of WEEE.

In addition to refining the current draftproposals, complementary measures shouldbe introduced that would support the objec-tives of the Directive. Some suggestions aresummarized in Table 3.

Table 3. Selected measures to reinforce the WEEE Directive

Accountability Clear consequences for member states that fail to meet minimum recoveryrequirements. Independently verified national data on waste volumes and product lifespans.Active support by member states to promote sustainable product design.DesignStrategies to encourage the re-use of products and components.Re-use

Research Further research into dangerous substances and their possible substitutes.Links to related measures such as eco-labelling and other forms of environmentalIntegrated product policyproduct information.The introduction of quantity based user fees for all household waste. Ecological taxFiscal incentivesreform. Measures to promote the use of recyclate.


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The basic objectives of the proposed legisla-tion are accepted by the stakeholders. Theimplications are, however, potentially moreprofound than is sometimes acknowledged orrecognized. Industry will be expected to man-age product life cycle phases hitherto re-garded as beyond ‘core business’. This couldresult in manufacturers concluding that, asthey are responsible not only at the start ofthe product life cycle but also at the end, thereis a logic, in terms of maintaining control, inretaining ownership throughout the cycle: inother words, leasing products rather than sell-ing them. This represents a challenge to themodel of personal ownership which lies at theheart of modern consumerism. Another exam-ple relates to the inclusion of small applianceswithin the scope of the legislation. This isjustified on the basis that such products con-tain a relatively high proportion of dangeroussubstances, but their inclusion also broadensthe influence of the legislation such that a fargreater number of consumer decisions will beaffected by it.

Any legislation needs to be implementedeffectively in order to be successful. The com-mitment of individual member states will becritical. There will need to be incentives toensure that the minimum recovery require-ments established are met throughout the Eu-ropean Union. The type of infrastructure forcollection and recovery must be carefullyplanned, as it will be an important determi-nant of costs and the impact on waste-relatedtransport. There is also a need to determinewhether to provide public funding for sys-tems of disassembly, repair and refurbish-ment that invest in ‘social labour’ and localeconomic development, which would exploitthe training and employment potential of theproposals.

The pace of progress of EU legislation isdetermined by many factors: perceived ur-gency, its complexity, the level of controversywithin and between member states and theextent of flexibility in the draft proposals.Delays have already occurred in progressingthe Directive because of the need to gainmaximum support within the EuropeanUnion. Further delays are possible as UnitedStates interest groups argue that the European

Union should wait for global solutions (Elec-tronic Industries Alliance, 1999; ENDS, 1996).Once the proposals are published as a draftDirective they must be accepted by the Eu-ropean Parliament and approved by theCouncil, a process likely to take two years.Member states are then allowed 18 months inwhich to transpose the legislation, which sug-gests that it is unlikely to be in force before2004. This suggests that member states willneed to be pro-active in developing nationalpolicy if they are to meet the initial require-ments of the Directive.

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WEEE, WEEE, WEEE, WEEE, all the way home? An evaluation of proposed electrical and electronic waste...

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Transcript of WEEE, WEEE, WEEE, WEEE, all the way home? An evaluation of proposed electrical and electronic waste...