OpenLobby.EU
Explore

EucoLight

EucoLight

EucoLight is voice of European WEEE compliance schemes specialised in managing the collection and recycling of WEEE lamps and lighting; working to make the circular economy a reality for lighting products.

Lobbying Activity

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

EUCOLIGHT, herewith raises a series of issues for consideration in the context of the WEEE Directive evaluation and makes detailed recommendations in the annexed pdf: 1.- WEEE definitions. In several MS (e.g., CZ, PL, RO), integrated LED luminaires are considered as lamps, which is not accurate, nor in line with the reference Guidelines by EWRN on the WEEE open scope. The annexes of the WEEE Directive should better define luminaires in categories 4 and 5 as to include integrated LED luminaires. 2.- Subcategories for lighting. MS use different WEEE subcategories. This implies considerable administrative burden for both international producers and registers. Harmonising subcategories in the next WEEE legislation is desirable. 3.- Reinforced data transparency requirements and control mechanisms for all actors of the supply and waste management chain beyond producers affiliated with producer take-back systems. This is a must for the proper enforcement of extended producer responsibility obligations for WEEE. We make recommendations e.g., transparency of data from national registers, including mandatory POM reporting, better cooperation, and coordination between authorities. 4.- The online-free riding issue. The level of non-compliant products supplied through online marketplaces in the EU market is still alarming notably for light bulbs and other WEEE. EUCOLIGHT just updated a study undertaken in 2019 whose results in 8 countries (CZ, BE, DE, DK, ES, IT, RO, PT) show that the non-compliance figures are still very high. We urge the EU to establish, once for good, the appropriate framework to tackle this unfair situation. We make practical recommendations e.g., compulsory verification, or marketplace deemed to be the producer, rendering sales for non-compliant product impossible, mandatory registration number in all commercial transactions 5.- Collective vs individual take-back systems. In some MS, individual take-back systems are not subject to the same rules as collective ones, leading some producers to opt for individual models to avoid extended producer responsibility obligations. Consequence: unfair advantages and increased burden on other agents. Solution: clear criteria and same obligations for individual and collective systems. Some MS have a solution (AT, CZ). 6.- Requirements for producers leaving a take-back system. Challenges about how to calculate the collection rate when a producer leaves during a given year have been reported. In RO a take-back system has no collection target for the first year, which generates compliance and financial issues. Solution: regulate producers departing conditions at EU level. CZ regulations offer a solution. 7.- Waste available for collection. Part of the waste available is not handled by established producer take-back systems due to e.g., sorting errors by (household) waste holders. It is the time to think about another approach considering waste held by all involved actors. 8.- Visible fee. It is a fine tool for WEEE financing transparency, and helps solving several issues at national level e.g., discounts on waste management fees from some take-back schemes to some big producers. The visible fee situation varies across the EU (from obligation to prohibition). A lack of clarity of national laws is reported (e.g., in CZ). Consequently, EU legislation to be more specific when MS render the visible fee mandatory. 9.- Eco-modulation of the fees. We call on the Commission to be cautious with the adoption of any criteria in this field. We undertook a study that demonstrated the absence of real benefit in modulating WEEE fees for lighting products. A comprehensive study by WEEE Forum and other stakeholders has further demonstrated that there was very little room to reduce technical treatment costs through treating greener products and huge limitations to delivering a product or consumer change through eco modulation.
Read full response

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

EUCOLIGHT, the European association of lighting WEEE compliance schemes welcomes the European Commission initiative to review the waste framework Directive and its objective to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle, potentially via Extended Producer Responsibility schemes. Taking into consideration the Green Deal and Circular Economy Action Plan, EUCOLIGHT recommends that the revised EU waste framework embraces the principles of the circular economy, in the full implementation of the provisions on waste prevention, preparation for re-use and recycling. In the attached paper, EUCOLIGHT makes a series of recommendations on: - extended producer responsibility requirements that have not been adequately addressed in Article 8a of the 2018 Directive or for which the compliance should be improved; - accuracy of EEE and WEEE data, and the need to avoid contamination of waste streams; - the collection of end of life products under EPR policies; - fee modulation; - Improving enforcement of EPR requirements, in particular for products sold online to customers in the EU.
Read full response

Response to Registration and reporting of producers of WEEE and the frequency of reporting to the register

8 Mar 2018

EucoLight is the European Association of lighting WEEE compliance schemes. DRAFT REGULATION: - Frequency of actualisation / updating to the register information is missing (e.g. list of member states in which the products sells EEE by distance selling, must be updated to be useful for control of free-riders etc) - Entry into force with 1.1.2019 isn't realistic, this should be changed to 1.1.2020, because of technical adaptation of registers and for the producers. ANNEX I - The European tax number should be identical to the national tax number and therefore is should be requested once. - Producer responsibility: when declaring whether a manufacturer fulfils his obligations individually or by participating in a system, a choice for households or business should be added. The same manufacturer can participate in a system with their B2C quantities and fulfil its obligations for B2B individually. - Part A: It is irrelevant to ask producers, when registering, to declare the categories and subcategories of products they intend to place on the market. They may not necessarily know. In any case this data will be provided automatically when they complete their quarterly/annual POM reports. This is an unnecessary additional burden on producers, given that this regulation is intended to reduce burden on producers. - Part B: The same comment applies to Authorised Representative registration. It is irrelevant to ask ARs, when registering, to declare the categories and subcategories of products they intend to place on the market. The may not necessarily know. In any case this data will be provided automatically when they complete their POM reports. This is unnecessary additional burden on ARs, given that this Regulation is intended to reduce burdens. ANNEX II - National identification code: as alternative a EEE-registration code should be possible for the identification. - National tax number / contact person for the reporting: as these data are already given at the time of registration, a re-entry is not required for each report. - The requirement in Annex II to report per category of EEE (M) and per sub-category of EEE (M*) is unnecessary duplication, and adds a burden on producers and third parties representing producers. If subcategories are applied, there is no need to require producers to also report by category. We therefore recommend that this is changed to Report per category (M OR) report by sub-category of EEE (OR M). - Lamps are already in a separated category in the WEEE Directive 2012/19/EU - why specifically ask for a separate declaration of lamps in this Regulation?
Read full response

Response to Methodology for the calculation of the weight of EEE placed on the market and of WEEE generated

23 Dec 2016

The European Association of lighting WEEEE compliance schemes (www.eucolight.org) observes major shortcomings for the lighting sector with this Draft Implementing Regulation and cannot support it as presented: - EEE lamp data used in the calculation tool materially incorrect, - calculation tool not part of the consultation process, therefore cannot be commented. Main Issues: 1. Inaccurate statistics in the UNU model, which is the basis of the pre-populated data included in the calculation tool supporting the Draft Implementing Regulation: • Considerable discrepancy (in some countries: 2 fold increase) between the UNU statistics (based on PRODCOM codes and Combined Nomenclature codes- CN codes) pre-populated in the calculation tool, and the actual data recorded in those Member States. The data contained within the calculation tool is incorrect. • In those Member States which do not have information from National Registers, the use of statistics from PRODCOM codes and Combined Nomenclature codes-CN codes (in order to calculate EEE POM) is not reliable. PRODCOM data are proven inaccurate for lamps EEE put on the market according to a comparison done in some Member States with the information provided by National Registers. Furthermore, no CN Codes existed for LED lamps. • Uncertainty as to whether PRODCOM codes and CN codes used do actually provide matched information with EEE under the scope of the WEEE Directive and if no other non EEE-related information have been declared under those codes. 2. Technical issues in the UNU – Keys classification in the calculation model supporting the Draft Implementing Regulation • Incorrect definition and wording of UNU-keys 0501, 0505, 05056 for lighting products not correctly aligned with the legally applicable EEE categories contained in WEEE Recast Directive. Proposed solution: • clarification in the legislation Inclusion of the following wording in the preamble of the Implementing Regulation in indent number (7) : “(7) For the calculation of the total quantity of WEEE generated in a given year in the territory of a Member State, it is important that Member States use a common methodology, that takes into account data on the quantity of EEE placed on the market of each Member State in the past, data on the lifespans of different EEE, according to its type, the level of saturation of the national market and the differing life-cycles of EEE in the Member States. A WEEE calculation tool based on this methodology should be available for use by Member States and pre-populated with the necessary data to allow its direct application. Member States should confirm the adequacy of the information pre- populated in the calculation tool and if necessary, to be given the possibility to update the data used in the tool on EEE placed on the market for past years and/or lifespan data, based on relevant data, included National Register data according to article 16(2)c, and evidence to support such updates. • Required changes for UNU keys: o 0501 > : “Small lighting equipment, excl. LED & incandescent”; 0505 > LED lamps (incl. retrofits LED lamps); 0506 > Household luminaires (incl household incandescent fittings & household LED luminaires); o Change of lifetime profiles for the LED lamps in the calculation tool. Originally established in 4 years and now adjusted to 10 years. These changes are essential. No warning or disclaimer in the Implementing Regulation would be highly detrimental and create legal uncertainty for producers of EEE and their compliance schemes. Unchanged UNU key would lead to unachievable collection targets. Finally, overall the assessment is very difficult to the fact that the calculation tool is not part of the public consultation. So we would encourage the Member States to verify that the above-proposed changes are implemented.
Read full response