Orgalime, the European federation of major trade associations, has released its core responses to the transposition of the WEEE Directive.
Not to be confused with the current consultation taking place at UK level it, nevertheless, emphasises some of the key points that UK government needs to address when considering the UK transposition. In particular it highlights that most WEEE (and used EEE) does not enter the WEEE system and is therefore not currently counted towards the targets. While BIS has acknowledged this fact, and has put forward proposals to count WEEE being recycled (but not recorded) by scrap merchants, some believe that this does not go far enough and that other outlets, in particular for used EEE, need to be taken into account which would entail identifying activities not only outside of the WEEE system but outside of the waste system.
The Orgalime response can be accessed here