B2B Compliance, the largely non-household focused Producer Compliance Scheme, has responded to the recent report from a group representing Europe’s WEEE recyclers which has called for governments to use the transposition of the Recast WEEE Directive to capture the estimated one third of WEEE being recycled outside of producer take-back schemes and which has called for enforcement of mandatory reporting obligations for all permitted reprocessors of WEEE in order to meet targets being brought in under the Recast.

David Burton, Project Director, stated “While we welcome the report which seeks to encourage wider data capture, there has to be a recognition, at both operator and political levels, that probably an even greater percentage of used electrical and electronic equipment (EEE) doesn’t appear as WEEE in the first place. It would not be realistic to argue that a third of used IT, for example, ends up uncounted in scrap yards when significant added value markets exist. Furthermore much business-to-business EEE is deployed under extensive long term maintenance contracts and subject to constant updating with spare parts and, ultimately, stripped for spares – in all circumstances the spare parts are out of scope and the discarded shells, not being complete products, are not WEEE by definition. Fortunately, Article 16 2.(4) of the Recast states that Member States shall collect information, including substantiated estimates, on an 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. The potential use of Substantiated Estimates within the Recast, and by extension, the development of protocols to count that which isn’t being counted, ought to enable us to look beyond waste and at true life cycles of products placed onto the market.”