The European Commission’s draft Guidelines on the “general minimum requirements for Extended Producer Responsibility (EPR) schemes” set out in Directive 2018/851/EU aim to facilitate the adaptation of EPR schemes to new requirements concerning eco-modulation of fees by providing guidance to support their harmonised interpretation and application across the EU. They say: “Harmonised and effective implementation of these requirements should support level playing field and provide investment certainty, in particular, in separate collection, sorting and recycling, which will then go counter to the intended harmonisation and to increasing the effectiveness of such schemes across the Union.”
In response to these Guidelines, the WEEE Forum set up, towards the end of 2020, a multi-stakeholder task force, including APPLiA and individual producers representative of DIGITALEUROPE, the sector’s producer associations, as well as the forty-five producer responsibility organisations (PRO) in the WEEE Forum, to proactively develop a preferred framework, principles, and mechanisms for a harmonised eco-modulated fee scheme in Europe and to assess its economic impact.
In July 2021 the task force came to the following chief conclusion:
It is impossible to have a wide, comprehensive, and ambitious scheme where EPR financial contributions do not exceed “the costs that are necessary to provide waste management services in a cost-efficient way” (as stipulated in legislation), and yet has a discernible effect on consumer and producer behaviour.
‘Eco-modulation of fees for ‘greener’ products‘
Eco-modulation_Annex I_Directive 2018.851.EU_Article 8a4
Eco-modulation_Annex II_Eco-modulation_Sofies study_Economic assessment
Eco-modulation_Annex III Consumer Survey 2021
Eco-modulation_Annex IV Synthèse étude Modulation OCAD3E EN
Eco-modulation_Annex V Eco Modulation Joint Industry Comments 2019
Eco-modulation_Annex VI Eco Modulation EucoLight Study 2020
The WEEE Forum a.i.s.b.l. is an international association representing fifty producer responsibility organisations across the globe. Together with our members, we are at the forefront of turning the extended producer responsibility principle into an effective electronic waste management policy approach through our combined knowledge of the technical, business and operational aspects of collection, logistics, de-pollution, processing, preparing for reuse and reporting of e-waste. Our mission is to be the world’s foremost e-waste competence centre excelling in the implementation of the circularity principle.
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