In an open letter to MEP Jill Evans, the associations EERA, FEAD and Eurometrec commented to the "Draft Report on the proposal for a directive of the European Parliament and of the Council on the restriction of the use of certain hazardous substances in electrical and electronic equipment ". EERA, FEAD and Eurometrec are representing the voices and core technologies and competences of recycling of End©\of©\Life electrical and electronic equipments (WEEE) in Europe.
|EERA, FEAD, Eurometrec|
The fundamental comments of the three associations are:
1. Investments in research and development of new recycling technologies and the use of post consumer recycled content is becoming ncreasingly important among the producers and suppliers of electronic products around the globe and in Europe. Therefore new proposed legislation related to the recycling of end©\of©\life electronic equipment should be based upon up-to-date risk assessments and take into account these latest and new recycling techniques in order to further stimulate those investments and developments and offer differentiation between electronic producers, suppliers and recyclers ;
2. The current RoHS recast is not aligned with REACH; we do not understand why one given substance is considered as a substance of concern under one piece of legislation, whereas under another piece of legislation the same substance does not pose any risk. Such differences will create legal uncertainty for this upcoming technology and industry and will lead to unnecessary duplication of procedures or conflicting requirements on electrical and electronic equipment ;
3. Technology to separate brominated flame retardants from plastics - so that plastics recycling from complex mixtures of WEEE becomes possible ©\ does exist and is available in Europe. Recycling shows clear environmental benefits ¨C especially in the aspect of CO2 emissions. The use of such recycled plastics should be stimulated in view of these because there are clear socio©\economic and environmental advantages both in the production (virgin vs. recycled plastics) as well as the end©\of©\life stage (recycling vs. thermal recovery).
In the enclosed annex paper the three organisations have further elaborated our concerns based on the current suggested amendments in the draft report. They are surprised and concerned by the statement that ¡°the recycling of WEEE containing brominated flame retardants, chlorinated flame retardants, PVC and its hazardous plasticisers provides no environmental benefit and is uneconomical.¡± This statement is not corresponding at all with the current status of research, best available technology and developments in the field of recycling. On the contrary, the plastics recycling industry is developing fast and the consequence of adopting the proposals contained in amendments 6, 7 and 70 is likely to result in a slowing down of further developments and investments in this newly developing industry. This would jeopardize the recycling targets set by the WEEE Directive and the objectives of the EU Waste Framework Directive.
The full letter with annexes can be downloaded under eera-recyclers.com. Quelle: EERA, FEAD, Eurometrec