EPR to finance Re-Use? Matthias Neitsch, April 20, 2015 1
Yes! Why? 2
WEEE directive: Article 7 (1): each Member State shall ensure the implementation of the producer responsibility principle Art. 8 (3): Member States shall ensure that producers ( ) set up systems to provide for the recovery of WEEE using best available techniques. techniques Article 12 (1): Member States shall ensure that producers provide at least for the financing of the collection, treatment, recovery and environmentally sound disposal of WEEE from private households that has been deposited at collection facilities set up under Article 5(2). 3
WFD definitions: recovery: means any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy. treatment: means recovery or disposal operations, including preparation prior to recovery or disposal; best available techniques: means best available techniques as defined in Article 2(11) of Directive 96/61/EC. 4
WEEE directive re-read: re-read Article 7 (1): each Member State shall ensure the implementation of the producer responsibility principle Art. 8 (3): Member States shall ensure that producers ( ) set up systems to provide for the re-use of WEEE using repair & refurbishment. refurbishment Article 12 (1): Member States shall ensure that producers provide at least for the financing of the collection, reuse, repair & refurbishment of WEEE from private households that has been deposited at collection facilities set up under Article 5(2). 5
WEEE directive: Most member states did not comply!!! comply The commission did tolerate that!!! That means: official discrimination of re-use!!! officially accepted undermining of the Waste hierarchy!!! hierarchy 6
How much??? Transport from collection point to re-use facility + preparation for re-use (testing, repair, refurbishing, cleaning, sorting, retail...) sales revenues 7
ok, that's too complicated, so lets make a good bargain: same payment as for transport + recycling of equivalent WEEE category + xx % eco-bonus for best sustainable recovery performance 8
WEEE directive: Do producers have to pay for re-use now? No, not as long as member states do not fully transpose the WEEE directive into national law!!! Dear commission, please act!!! (instead, currently we are confronted with an injustifyable discriminatory standards development for preparation for re-use by CENELEC which we are obviously expected to pay by ourselves, while recyclers get paid by the producers 9
Some more important points: Economy of scale Mass flows Information for treatment facilities End of Waste 10
Economy of scale The more preparation for re-use happens, the cheaper it gets. This is why we need ambitious separate targets for preparation for re-use!!!! 11
potential of reusable WEEE Mass Flows: Pilot action in municipal collection centre Nenzing, 2014: 1.580 kg WEEE collected separately as potentially reusable = 18% of total collected big & small appliances 1.040 kg or 118 pieces effectively sold = 65 mass% of WEEE collected separately as potentially reusable 58% of pieces of WEEE collected separately as potentially reusable 12% of total collected big & small appliances Quelle: TB Hauer 12
Information for treatment facilities Art. 15 - Information for treatment facilities 1. In order to facilitate the preparation for re-use of WEEE, Member States shall take the necessary measures to ensure that producers provide information free of charge about preparation for re-use and treatment in respect of each type of new EEE. This information shall identify, as far as it is needed by centres which prepare for re-use the different EEE components and materials. It shall be made available to centres which prepare for re-use by producers of EEE in the form of manuals or by means of electronic media (e.g. CD-ROM, online services). Art. 24 3. Member States may transpose the provisions set out in (...) Article 15 by means of agreements between the competent authorities and the economic sectors concerned. concerned 13
End of Waste WFD, Article 5 By-products: By products can be classified as non waste, if: further use of the substance or object is certain; certain the substance or object can be used directly without any further processing other than normal industrial practice; the substance or object is produced as an integral part of a production process further use is lawful, lawful i.e. the substance or object fulfils all relevant product, environmental and health protection requirements for the specific use and will not lead to overall adverse environmental or human health impacts. Why not define end of waste for preparation for re-use in the same way??? 14
End of Waste Waste Non - Waste 15
Thank you for your attention! RepaNet Re-Use- and Repair Network Austria Association for re-use, resource protection and employment in environmental services A - 1040 Wien, Trappelgasse 3/1/18, Austria www.repanet.at Matthias Neitsch managing director neitsch@repanet.at +43 / 699 / 100 51 038