Issue paper: open scope

The WEEE Forum a.i.s.b.l., a global central of competence speaking for thirty-six producer responsibility organisations in Europe, Australasia and North America, acknowledges the different guidelines provided to improve the understanding of the so-called “Open Scope” of Directive 2012/19/EU (hereinafter “the Directive”).

This paper seeks to identify the consequences for the WEEE compliance and management sector of the different interpretations of the new scope. 

Main messages:

The WEEE Forum is of the opinion that:
► When setting up the new scope, decision makers should be mindful of implementation aspects, such as the achievement of the collection and recovery targets set by the WEEE legislation
► Execution of the measures to adapt to the new scope and classification will require appropriate planning and timing for all actors affected
► In order to keep a level playing field in Europe, there should be harmonized criteria to determine the products that fall in the scope of the Directive.
► An assessment of the impact of the inclusion of products belonging to the denominated “grey areas” in the BIO report should be conducted before its inclusion is agreed.
► The assessment should consider how the inclusion of such products will affect the management of WEEE from an environmental, legislative, technical and economic point of view.
► Decisions on new scope and classification should be accompanied by a bespoke communication and enforcement campaign to ensure compliance