Recast Waste Electrical and Electronic Equipment Directive ('WEEE2'): Comments on Draft Guidance Document ('FAQs')
Orgalime thanks the Commission for both, the possibility to comment on the Draft Frequently Asked Questions Document on Directive 2012/19/EU, and for tabling a draft, which we generally consider a largely pragmatic, well-structured and comprehensive basis for effectively clarifying certain aspects of the Directive and helping producers in their preparations for compliance.
Orgalime expresses its explicit support for the following sections of the draft FAQs:
The draft Q&As provided regarding the appointment and possible mandate of an authorised representative (Q 1.32 and 1.33)
The draft Q&As provided regarding separate collection/collection rate: we explicitly welcome the approach of including all routes and flows of WEEE for the future implementation of the Directive (Qs 1.19, 1.25 to 1.29). This will strengthen the environmental objectives of the Directive and the Commission’s wider resource efficiency policy. While we suggest removing the last paragraph of Q 1.23, we also welcome that Member States have been confirmed as the responsible addressees of the target in this entry.
The draft Q&As provided to secure a European approach to the marking obligations to provide information to treatment facilities (Q. 1.31).
The draft Q&As regarding annex VI on minimum requirements for shipments, including the suggested interpretation of certain derogations and documentation requirements in case of legal shipments (Qs 1.38, 1.39, 1.45).
Most parts of the draft Q&As regarding the understanding of the scope during the transition period, including the definition of “dependent”, the continuation of the existing ten scope categories during transition period, the notion “specifically designed” and exclusions of equipment that uses electrical energy only for support or control functions (Q 1.4, 1.12, 1.13, content of Q 1.3, appendix/part 2/criterion 2).
The draft Q&As provided regarding reuse (Q1.22).