EERA regularly publishes papers. Presentations in workshops and conferences are frequently given to express the views of the recyclers. Position papers, brochures and relevant other publications can be found below.
Work documents, minutes of meetings and results of surveys and research documents are only available for members.
EERA Members want the recovery of plastic from e-waste to continue, to be environmentally sound, and also to be TECHNICALLY POSSIBLE!
EERA Members urge MEPs and other stakeholders to consider these unintended consequences for thresholds below 500 ppm. Read more in our Position Statement (June 1 2022)
EERA and the European Battery Recyclers Association (EBRA) have sent a Joint Position Statement to the Members of the European Parliament, and European Commission in respect of the recent amendments put forward by the European Parliament.
The use of waste material as a secondary resource is one of the first actions that businesses could consider to improve both their economic and their environmental performance. Value chains are often cross border in nature and thus they require transboundary shipment of secondary resources. However, businesses perceive barriers in transborder shipment of waste and secondary resources. Many barriers are related to the uncertainty regarding the waste or resource status, the subsequent treatment of these wastes and hence on the waste shipment requirements.
Procedures to get clarity on waste or resource status are complex and time consuming. This can result in different interpretations between countries and so create confusion and a lack of legal certainty and clarity. Addressing these barriers and identifying shared solutions has the potential to accelerate the transition towards sustainable growth: this is what the North Sea Resources Roundabout (NSRR) aimed to achieve.
In light of the flurry of initiatives being developed by the EU’s Circular Economy Action Plan to bolster circularity and sustainability, the European Electronics Recyclers Association (EERA) wishes to put forth a series of recommendations for a review of the current WEEE Directive fromthe perspective of specialized European recyclers’ first-hand experiences in the management of WEEE.
EERA is the voice of WEEE recycling in Europe being the professional association for the
recycling and reprocessing industry. Our vision is for a resource efficient economy where WEEE is managed as a resource and is returned into the economy as a raw material or as equipment for re-use. A full recycling economy with market actors cooperating along the value chain, better collection processes, high quality recycling, appropriate regulatory framework, eradication of illegal practices and product design integrating a life-cycle approach is what EERA envisages.
Our mission is to achieve a level playing field for fair competition in the WEEE value chain, harmonisation of regulations, effective and efficient recycling and reprocessing with prevention of pollution, minimization of emissions and a high quality of secondary raw materials and components. Given the valuable and indispensable knowledge EERA members bring to the discussion on WEEE management in Europe, an independent survey conducted by Sofies was carried out in the form of an online questionnaire and intensive and focused interviews in order to gain recyclers’ views on the key points concerning the current WEEE Directive and its implementation in their national contexts.
The aims of the Circular Economy Action Plan are ambitious and quality WEEE recyclers, united in EERA, are eager to contribute to these goals, but the results of this survey show there is a need for sustainable rules, clear thresholds and a climate that stimulates investments in new recycling technologies.
Most importantly, the predominant takeaway from this survey is that there is an urgency to move away from a Directive and towards a Regulation to address the striking lack of harmonisation (and related negative impacts) between Member States WEEE management systems.
As follow-up of the publication of the proposals for a change in the Low POP Content thresholds for POP BFRs, as shared by the European Commission in October, EERA decided to write a paper in which EERA wishes to share its concerns about possible reductions of the POP BFR thresholds.
The paper explains, why we, WEEE recyclers, believe that the current POP BFR thresholds should be kept at the level of those that are included in the POP Regulation, that was published as recently as June 2019.
EERA also addressed concerns over possible proposals of the UTC thresholds. The paper should therefore not only be seen as the EERA response to the stakeholder consultation for the proposals of the Low POP Content threshold proposals.
We expect that the logic of our concerns will be understood and sincerely hope that the POP BFR threshold values will be kept at the POP Regulation of June 2021, as we strongly believe this to be the intelligent balance of the justified interests of both the Non-Toxic World objectives and those of the Circular Economy.
EERA recognized the Swiss - Ghana proposals as a serious threat for the European E- waste industry. EERA (author: Chris Slijkhuis, with input from our end processors) drafted a paper with comments on the Swiss - Ghana proposal for the Basel Convention and had an interesting discussion with the two authors of the proposal, Mr. Buletti, and Mr. Tschirren. Ther is a common view of the objective, namely that as much as possible E-Waste materials needs to be treated in compliant and state-of-the-art recycling processes. We identified that we have a different view of how to get there.
Instead of promoting the environmentally sound treatment of WEEE fractions such as printed circuit boards, copper and precious metal concentrates and WEEE plastics, these proposals are likely to make the transport of these WEEE fractions overseas to compliant end-processing plants, especially from developing nations, de-facto impossible.
This is exactly the opposite of what the Swiss/Ghana proposal intends to do, namely directing all WEEE its components and constituents moved transboundary to:
EERA has identified this issue as a major risk for the WEEE recycling industry, not only, but particularly for the WEEE end-processing industries, and is actively discussing these proposals with other organizations to document the consequences that these proposals will bring with them. If exports of these fractions are no longer possible in practice, this will create a global environmental problem, not only but particularly for developing countries, which often do not have technologies available for the end-processing of such WEEE fractions.
EERA is particularly pleased with the recognition of the practical problems with the PIC procedures that are not anymore in line with modern supply chain, especially deep sea and container transport, practices. In the attachment is the Swiss- Ghana proposal and the EERA paper.
EERA will follow up on in COP meetings and also at several occasions prior to next years’ OEWG and COP and will re-discuss these topics, identified by EERA as serious threat to the E-Waste recycling industry. It is expected to further discuss the review of the e-waste entries in Annexes VIII and IX on 13 January 2022.
The paper is also made available at Basel Convention website:
A project group for Fast Track Notifications started an adventure in 2017. Looking back, this group can be proud of the work done – as well the interest Fast Track Notifications has triggered the European Commission DG ENV: we have seen some of it incorporated in the consultation on the revision of the WSR.
The first Fast-Track pilot notification, for a shipment of WEEE between HKS Metals and Müller-Guttenbrunn, was approved on March 20 2019, setting the total time needed for approval by Dutch and Austrian authorities to 19 working days. This constitutes a very significant improvement compared to regular notification procedures, even those between so-called pre-consented facilities. Making shipments between compliant recyclers in the EU faster and easier may significantly boost the circular economy in Europe.
The working group took de initiative for a next step to produce concrete proposals on alternatives for the financial guarantees. There are several simple ways forward. The working group already suggested to not have any financial guarantee for fast-tracks, as the amount of administrative work is more costly than the incidence of any use of the financial guarantee. Another way forward could be to largely simplify the calculation of the financial guarantee.
The project group feels that the Commission should lead this work to make sure there is broad support from all interested and relevant parties for substantial simplifications of all business processes related to notifications, particularly to Fast-Track Notifications. The logic should be based on the principle that the competent authorities should be responsible for each of their own territory; today many of the competent authorities ask many questions of what is happening outside their area of competence – particularly for Fast Tracks this is in our view fundamentally wrong.
Some working group members suggested to not reconvene before the study on WSR is publicly available. Once the study from the consultants is available, the idea then is to conclude our Fast-Track Notification Working group collaboration by providing input to this study, based on our findings within our Fast-Track Notification working group. The European Commission promised to inform us as working group once the study is available and we will let you know as soon as this is the case.
WEEE Forum, EuRIC, EUCOBAT, EERA, MWE and the WEEELABEX Organisation join forces to counter the occurrence of fires caused by lithium batteries and e-waste containing lithium batteries. A new report compiles good practices addressed to all actors in the value chain and covering all phases of products’ lifecycle.
More and more electrical and electronic products in everyday life contain batteries, making life more convenient and pleasant. However, those same batteries, when damaged, also increasingly cause fires.
In the past few months, organisations representing the industry that manages the collection and treatment of spent batteries and electronic waste (WEEE) along with manufacturers of home appliances and consumer electronics, gathered to exchange views about this issue of growing concern in order to design measures to counter the frequent occurrence of fires. A survey among recyclers resulted in a better understanding of the issue of fires in the WEEE management chain. The report , “Recommendations for tackling fires caused by lithium batteries in WEEE”, has been prepared by the WEEE Forum and EuRIC with the active contribution of experts from various organisations including the co-signatories EERA, EUCOBAT, Municipal Waste Europe and the WEEELABEX Organisation. The report presents a set of recommendations and good practices aimed at countering the occurrence of fire incidents caused by lithium batteries and WEEE containing lithium batteries.
It is a fact that high energy batteries – mostly lithium type – are posing serious fire risks to WEEE recyclers. EERA calls on all stakeholders to implement ADR rules for the safe collection and transport of WEEE including batteries. 80 % of WEEE recycling companies report serious fires and related incidents at their facilities. The risk of fires is a serious cause of concern for the security and safety of employees at treatment facilities.
Recently EERA organised two workshops for members: “Sharing experiences and best practices with batteries in WEEE”
Manfred Fahrner, has summarized these experiences in a comprehensive report.
EERA calls on all stakeholders, EU and national rule makers and authorities, to contribute to improving the safety of the collection and treatment of WEEE.
One of the main conclusions is that all the safety measures and further experience cannot eliminate the inherent risks associated with batteries. It is important that the dangers from waste batteries are addressed as early as possible in the collection and recycling chain.
EERA hopes that this report will contribute to raising more awareness among politicians and stakeholders about the risks of fires caused by batteries in WEEE. EERA is looking forward to contribute to reducing the risks of fires, caused by batteries in WEEE.
BSEF (bromine industry association) has commissioned an important study conducted by Sofies: the Impacts of Brominated Flame Retardants on the Recycling of WEEE plastics in Europe. The report was launched in on online webinar on November 18 and Arthur Haarman also presented the results of this study in the EERA meeting of december 2nd for an audience of 25 EERA members.
Chris Slijkhuis contributed to the event of BSEF with an insightful overview related to the facts of recycling of WEEE plastics in Europe.
EERA contributed to the E waste world conference (online) https://www.ewaste-expo.com/ with two interesting presentations and a participation in the panel discussion, with strong statements from EERA’s side.
Manfred fahrner: Recycling and material markets functioning markets or a need for regulation?
Chris Slijkhuis: Fast Tracks a requirement for circular economy of electronics waste?
This document is meant as input for the guidance document on the classification of plastics wastes. EERA felt the need to provide some input for the guidance document for the classification of plastic wastes for quality recycling within the Europe, as EERA members need to be able to deliver WEEE plastics to compliant plastic recycling facilities in Europe without additional burdens (see also chapter 4.3 of the Circular Economy Action plan).
EERA reaction to second delegated act text to the implementation of the Norwegian Proposals. EERA calls for the result that all plastic mixes from the recycling of WEEE will be to be allowed to travel to environmentally sound treatment facilities within the EU under the waste code EU48 as amber waste with a procedure of prior consent (notification) and that these WEEE plastics will not be classified as hazardous with the A3210 code.
Find here the full statement: eera-reaction-latest-version-eu-delegated-act-norwegian-proposals-july-2020.pdf
The EU is working on a delegated act to be implemented in EU law because of the Norwegian proposals that have been implemented in the Basel Convention.
This implies that only separated and clean plastic waste may be exported as green listed material under a new B code, namely B3011.
All mixtures will become notifiable wastes under the code Y48. But the worrying issue is that “contaminated plastic wastes” (and the texts specifically mention “incl. halogenated plastics”) will be classified with a Basel A code, namely the new A3210 code.
EERA and EURIC represent the vast majority of technical plastics recyclers from Waste Electrical & Electronic Equipment (WEEE) and end-of-life vehicles (ELVs).
The plastics recycling industry has been severely impacted by the COVID-19 pandemic. Technical plastics recycled from ELVs and WEEE are no exception. Boosting the Technical Plastics Recycling in Europe is an urgent matter.
Read th efull document: 2020-07-06-euric-eera-joint-call-to-boost-technical-plastics-recycling.pdf
Extended Producer Responsibility (EPR) initiatives stemming from the Polluter Pays principle are being questioned right now when it comes to post-consumer recycled plastics (PCR). With the price of oil at historic low levels the cost of primary plastic is now lower than that of recycled polymers. The cost of collection, processing and production of quality recycled plastics has no index and these cost parameters are not associated with the price of oil.
PCR plastics cannot be indexed against the value of oil. Their origin is from a completely different source. National and European legislation for the collection, treatment, and conversion of plastic products such as waste packaging and WEEE derived plastics form the legal bases for the producer’s responsibility. The cost of recycling made up of environmental compliance, the complex legislative burden such as facility licencing and transboundary shipments, facility infrastructure, applied process and sorting technology, the cost and availability of incinerating plastics containing restricted substances and not least, manpower are not governed by the fluctuations of the oil market.
The Green Deal, Single Use Plastics Directive, Circular Economy Action Plan all need stronger enforcement of their goals. The mandatory content of WEEE derived PCR plastic such as that foreseen for PET beverage containers (30% by 2030) must become part of European and National laws. Taxation models to stimulate the content of PCR plastics in new products must be given serious consideration.
Right now, producers are conveniently forgetting their part in the circular economy. It is after all their products that the recycling industry are collecting and converting for use in new articles. Producers wishing to abandon their responsibilities towards the recycling industry to take advantage of primary plastic prices right now need to look carefully at consumer demand for circular use of plastics. The resistance to consume PCR plastics by producers will affect Fee Modulation calculations where products with no recycled plastic content will be charged a higher rate when placed on the market. Environmental performance labels along with energy efficiency labels will give the consumer a clear choice as to who is following the demand for recycled products.
Ultimately the cost of EPR ends up with the consumer. Whether it is the cost of design, manufacture, or distribution, it all forms part of the price of the product. So too does the cost of end of life care from part of the product price. Consumers will ultimately demand the content of recycled material in their product purchase choices. The feel-good factor for consumers when they deposit an old electrical appliance for recycling that it will one day end up as part of something new is growing. Putting plastic recycling out of business for short term gain is not what is needed now.
EERA is taking part in the roundtable group charactisation of fires caused by batteries in WEEE. The result of a extensive survey is the final report and can be used for free and can also be found at EERA website- news: https://eerarecyclers-site.e-captain.nl
The outcomes are quite similar to the outcomes of our own study related to this topic. Our press release from April 2019 is also attached.
The roundtable group will now focus on Part B: best practices for WEEE equipment with batteries.
It was EERA who initiated the idea of a survey related to fires caused by batteries in WEEE and this was taken over by this roundtable group. EERA would like to thank Manfred Fahrner, senior expert for all his contributions to this study.
EERA is often asked to provide figures on the state of play on collection of plastics from WEEE in Europe. EERA expert Chris Slijkhuis decided to make an update with new realistic figures based on the CWIT report (2015), the Urban Mine Platform figures and estimations based on the European WEEE market. With the growth of the WEEE market since 2012 the WEEE plastics volumes are estimated to be 1.4 Mio MT – of which approximately 50 % from officially collected and report volumes. The capacity for the treatment of this volume of WEEE plastics in Europe is much smaller.
What we also see is that the average plastics content is fairly stable with: Small Appliances & Consumer IT some: 28%, Large Domestic Appliances: 15%, Temperature Exchange Equipment: 17% and screens (with the current mix of CRT and Flat Panel Displays): 22%.
Link to the presentation: just click on the heading.
However the mix of plastics has changed quite a bit over the last 8 years – particularly the average amount of High-Impact PS has reduced considerably and an important reason is the disappearing CRT fraction as well as the replacement of HIPS by PC and PC/ABS in particularly Flat Panel Displays and the Set-Up boxes and modems. Also the content of PP in Household Appliances has increased.
Feedback on “Study on Quality Standards for the Treatment of WEEE”
EERA, the European Electronics Recyclers Association, has taken note of the four books (background documents) that constitute the study on quality standards for the treatment of waste electrical and electronic equipment (WEEE).
EERA strongly supports Option One over the other options presented in BD III “Options for EU WEEE treatment requirements”. For many years EERA has expressed the view that it is of great importancethat the European Commission adopt an Implementing Regulation, in accordance with the provisions laid down in article 8(5) of the Directive, to make compliance with and certification to the EN 50625 and EN 501614, covering the collection, logistics, preparation for reuse and treatment of WEEE, mandatory in Europe. This is the best way forward to create a level playing field across the EU.
EERA report highlights huge scavenging problem across Europe
The scavenging of waste electrical and electronic equipment (WEEE) across Europe, which essentially means e-waste or components of e-waste, stolen or misappropriated for financial gain, is a huge problem which has been highlighted by the European Electronics Recyclers Association (EERA).
In 2019, EERA Members and other EU recyclers provided data relating to 2018 levels of scavenging, encompassing 520,000 tonnes of WEEE treated in 43 treatment locations across 9 different countries. Astoundingly, according to the report findings, the value of scavenged materials in 2018 was €151 million.
Apart from the financial losses to waste compliance schemes and compliant recycling companies, there is a massive impact on the environment which cannot be ignored.
To give just one example, the scavenging level of compressors is very concerning due to the release of ozone depleting gasses contained in the refrigeration circuit into the environment. According to EERA’s research, this would equal 3.6 million tonnes of CO2 equivalent, or the annual emissions of 2 million cars.
Read the report in full along with the recommendations made by Sofies, who conducted the study. eera-scavenging-folder-online-4.pdf
Opposing policies of the WEEE Directive (2012/19/EU) undermine growth in the
proper treatment of WEEE in Europe.
Article 16, paragraph 4: “Member states shall collect information, including
substantiated estimates, on annual basis, on the quantities and categories of EEE placed
on their markets, collected through all routes, prepared for re-use, recycled and
recovered within the Member State, and on separately collected WEEE exported by weight.”
EERA believes that these substantiated estimated volumes are affecting the proper collection, logistics and treatment of WEEE. Informal collections/recycling volumes are 34% of the EU total. These substantiated estimated volumes are often based on analysis of the input material of large shredders.
EERA highlights the unfairness of the use of substantiated estimates. EERA recommends that Member States should be restricted in the continued use of substantiated estimates and a definitive timeline set out for them to be eliminated.
EERA technical guidance document. Safe collection and transport of electronic equipment with lithium batteries. Understanding ADR rules made easy.
The situation with respect to the recast POP regulation is becoming very critical and the way it looks now it could be very negative for the recycling of WEEE Plastics in particular and with seriousconsequences for the recycling of WEEE in general. The original position of the ENVIE committee in
the European Parliament was that the UTC value for concentrations of decaBDE should be equal to or below 10 mg/kg (0,001 % by weight) when it occurs in substances, mixtures, articles. When this will be adopted by Parliament and Council, it will mean that recycling of WEEE plastics will becomeimpossible in Europe.
EERA proposes the following amendment, which would allow WEEE plastics industry to continue to work.
The new brochure responsible recycling of CRT's is published.
This study, gives reliable insight in the operational costs of compliant recycling of WEEE and the widespread selective "scavenging"of products and components and materials.
13 EERA members, encompassing 27 treatment locations in 13 countries for a total volume reported of 465,000 tons, provided data over 2016., for various collection categories.
Open link for results and recommendations in this publication.
Joint position on the Recast of the Persistent Organic Pollutants (POPs) Regulation (EC 850/2004)
Impact on plastics recycling of setting a disproportionately low unintentional trace contaminant (UTC) threshold (10 mg/kg) for decaBDE in Annex I of the POP Regulation.
There is a serious concern on the amendments tabled by the European Parliament to set, in Annex I of the EU POP Regulation, a limit regarding the “unintentional trace contaminant” (UTC) for decaBDE at concentrations “equal to or below 10 mg/kg (0.001 % by weight) [i.e. 10 ppm] when it occurs in substances, mixtures, articles or as constituents of the flame-retarded parts of articles “.
EERA published a brochure which decribes how WEEE recyclers treat mixed plastics with Best Available Technology in compliance with WEEE and POP regulation.
Link to the call for Tender (e Tender):
The European Commission DG Environment, comissioned a study WEEE Compliance Promotion Exercise in 2017. The final report is published. Click here to download a copy of the final report of the WEEE Compliance Promotion Exercise.
Presentation dr. Jaco Huisman, IERC Salzburg 2018