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European Electronics Recyclers Association

EERA

EERA is a non-profit trade organisation is the voice of Waste Electrical and Electronic Equipment recovery facilities in the continent of Europe, being the professional Association for the re-use, recycling, and re-processing industry.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

3 Dec 2025

Call for Evidence EU Taxonomy Review (Climate & Environmental Delegated Acts) EERA Response to the European Commission The European Electronic Recyclers Association (EERA), representing Europes leading professional Waste Electrical and Electronic Equipment (WEEE) treatment, depollution and resource recovery operators, welcomes the opportunity to contribute to the European Commissions review of the Climate and Environmental Delegated Acts under the EU Taxonomy Regulation. EERA fully supports the Commission's goals of making the Taxonomy framework easier to use, legally consistent, and proportional. In the WEEE sector, many technical methods for compliance already exist in EU law. The main challenge is achieving legal alignment, harmonisation and clear interpretations across the Taxonomy, the WEEE Directive, the Waste Framework Directive (WFD), the Batteries Regulation, and chemical laws. EERA observes that recent draft guidance (2024) from the Commission mentions WEEE in the context of Activity 2.3 (collection and transport of waste). Although not formally adopted yet, this draft indicates that the Commission prioritises WEEE as a waste stream that needs high-quality separate collection. To maintain coherence across the value chain, we urgently need similar clarity for downstream WEEE treatment, depollution, hazardous waste handling, and critical raw material (CRM) recovery under Activities 2.4 and 5.9. EERA's submission aims to remove legal ambiguity, improve consistency among Member States, and ensure that the Taxonomy can effectively support high-quality WEEE treatment and critical raw material (CRM) recovery. See the attached file for our full statement and recommendations.
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Response to Circular Economy Act

30 Oct 2025

The European Electronics Recyclers Association (EERA) welcomes the opportunity to respond to the European Commissions consultation on the Circular Economy Act (CEA). Our responses draw on EERAs established policy positions on the Waste Shipment Regulation, Critical Raw Materials recovery, plastics recycling and end-of-waste criteria, Extended Producer Responsibility (EPR), and the recommendations set out in 'Towards EU WEEE Regulations'. This submission reflects the collective expertise of Europes leading e-waste recyclers, treatment facilities, and reprocessors. PLEASE SEE OUR ATTACHED RESPONSE
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Response to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252

24 Jul 2025

EERA welcome the opportunity to respond to the European Commissions consultation on the implementation of Article 26 of the Critical Raw Materials Act (CRMA), which provides for the establishment of a list of products, components and waste streams with high potential for the recovery of critical raw materials (CRMs). EERA represents long-established industrial actors specialising in the collection, dismantling and recycling of complex end-of-life products, particularly waste electrical and electronic equipment (WEEE), of which contain significant amounts of CRMs. We therefore offer a practical perspective grounded in real-world recovery operations. 1. Strong Support for a Targeted and Coherent List We support the Commissions intention to develop a focused and dynamic list of CRM-rich products, components and waste streams. Such a list, if appropriately scoped, can guide Member States in developing effective national circularity programmes, inform investment in recovery technologies, and promote higher-value recycling. We urge, however, that the guiding principle must be the polluter pays and that the list be coherent with existing legislative frameworks such as the WEEE Directive, Waste Shipment Regulation, and Waste Framework Directive, to avoid fragmentation or duplication. 2. Technical and Economic Viability Must Be the Cornerstone The e-waste recycling sector wishes to emphasise that they are ready to play their part, but have a fundamental concern: the recovery of CRMs must be both technically feasible and, critically, economically viable. Without both conditions being met, meaningful scaling of recovery operations will not be possible and investment and capital raising regardless of policy ambition. The cost of recycling must be borne by the pollutersnamely, the Producer Responsibility Organisations (PROs) and Original Equipment Manufacturers (OEMs). Several key factors determine the viability of CRM recovery: The global market: The value of output CRMs is dictated by fluctuating global commodity prices and demand, which are beyond the control of recyclers or Member States. European recyclers must compete on a global scale, and the high cost of energy and regulatory compliance often makes this impossible. Cost of recovery: Recovery and refinement processes are capital-intensive. They require advanced technologies, skilled personnel, strict environmental controls, significant administrative oversight, and increasing energy inputs. Regulatory and operational risk: Investing in CRM recovery infrastructure involves long-term commitment and exposure to regulatory uncertainty, particularly where policy targets are set without realistic economic baselines. We therefore caution against the premature imposition of binding or de facto recovery targets before robust economic assessments are carried out for each listed stream. The inclusion of a product or waste stream in the Article 26 list should be preceded by evidence that its recovery is commercially sustainable under current or foreseeable conditions. 3. Priority Waste Streams for Consideration Notwithstanding the above, we recommend that the Commission prioritise the following waste streams and components for further assessment, given their known CRM content and partial recovery feasibility: WEEE: o Printed Circuit Boards (PCBs) o Hard disk drives o Permanent magnets (e.g. neodymium in motors and speakers) o LCD films (containing indium) o Phosphors from fluorescent lamps o Cables o PV panels However, even for these streams, full recovery is only justified where material concentrations are high enough, and the cost-benefit ratio supports sustainable operations. We would like to point out that although (partial) dismantling will, in specific cases, be beneficial for higher CRM recovery, this is not necessarily always the case. We should avoid any obligation for WEEE and/or components to be mandatorily manually dismantled as this will not provide the benefit
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Initial Observations on the European Commissions Digital Product Passport (DPP) Proposal Joint Submission by EBRA and EERA December 2024 As representatives of the European waste management sector, for electronics and batteries, EBRA and EERA welcome the opportunity to provide initial observations regarding the European Commissions proposals for the Digital Product Passport (DPP). We understand that under the Ecodesign for Sustainable Products Regulation (ESPR 2024), the DPP is intended to cover a wide range of product categories and being experts in the end-of-life sector for batteries and consumer electronics and electronic devices our comments relate to these types only. Given the diversity and complexity of these categories, it is clear that at this stage only broad principles can be considered, as the practical implementation of the DPP remains uncertain. Please see the attached response for the details of our response Thank you EBRA and EERA
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

Thank you for the opportunity to provide feedback. Please see attached.
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Response to Waste Electric and Electronic Equipment

10 Feb 2023

We support the Commission in the amendments proposed. EERA is a non-profit organisation and is the voice of WEEE recycling in Europe being the professional association for the re-use, recycling and re-processing industry. Our vision is for a resource efficient economy where WEEE is managed as a resource and is returned into the economy as a secondary raw material or as equipment prepared for re-use. Our mission is to achieve a level playing field for fair competition in the WEEE value chain, harmonisation of regulations, effective and efficient recycling, and reprocessing with prevention of pollution, minimization of emissions, and a high quality of secondary raw materials and components. www.eera-recyclers.com
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Response to Ecodesign for Sustainable Products - Product priorities

10 Feb 2023

EERA welcomes the overall objectives and aspirations of the proposed Regulation on Ecodesign for Sustainable Products (ESPR), as it has long been our viewpoint that the key to good recycling opportunities to recover secondary materials must begin at the design stage. This is so there is prior consideration of the lifecycle; consumer use and the second life of products (re-use); and then the discarding of the product as waste for recycling and the recovery and processing of the materials within all products. Please see our response in full in the attached document.
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Response to Measures addressing the environmental impact of imaging equipment including consumables

10 Feb 2023

EERA welcomes the overall objectives and aspirations of the proposed Regulation on Ecodesign for Sustainable Products (ESPR), as it has long been our viewpoint that the key to good recycling opportunities to recover secondary materials must begin at the design stage. This is so there is prior consideration of the lifecycle; consumer use and the second life of products (re-use); and then the discarding of the product as waste for recycling and the recovery and processing of the materials within all products. Please refer to our attached document to see our complete response.
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Response to European Critical Raw Materials Act

25 Nov 2022

The European Electronics Recyclers Association (EERA) notes that this initiative will create new jobs and industry growth and provide security for Europe. We recognise that action must be undertaken at the EU level to ensure the supply of key CRMs as it will be impossible to implement and negotiate at Member State level given the lack of harmonisation in regulations and single market initiatives. Recovery of CRMs: The ambitions of the circular economy objectives and European Green Deal must be reflected in all areas of the recovery of CRMs and other materials derived through the responsible collection and recycling of end-of-life electronic products and batteries. Please see our attached paper for full details of our opinions and recommendations. The following represents the summary list of the issues that we believe need to be considered: Consumer Awareness: It is essential that consumers are incentivised to return end-of life products and batteries at their end-of life. Collection of e-waste and batteries: Public awareness should be increased to provide information on the compliant collection options. Social importance: Public awareness should include the environmental, economic, and social importance of CRMs. Mandatory handover of all e-waste and batteries: It is critical that e-waste is handed over only to responsible operators through approved collection schemes provided by producer responsibility organisations (PROs) to prevent scavenging. Non-household appliances: These should be handed over to responsible operators at the end-of-life / end-of European market potential to approved collection schemes provided by PROs as often the onward routes for B2B are uncertain and so to prevent the loss of valuable CRMs within Europe. Enforcement: Action needs to be taken to reduce the illegal trade of e-waste and components from e-waste. This should include checks and action on the used and second-hand equipment market as evidence shows that often this equipment is untested and non-functional and is going for sham re-use. Projects: Need to be identified and established so that solutions can reached, even if initially these are subsidised artificially through market price support. Recovery targets: Quality-focused targets relating to e-waste and battery recycling should be imposed so that there is a focus on the recovery of key CRMs. Recovery Barriers: EERA have identified that the main barriers to recovery of CRMs within Europe are the lack of market drivers being: the economic viability of CRM recovery in Europe; the lack of information on where key CRMs can be found; and (in the case of some specific CRMs) the absence of recycling and recovery technology. EERA recommends: The identification of key CRMs is a priority - where they can be found (e.g. listed by manufacturers in a product passport etc.) and how they may be recovered (e.g. identification, removability etc.). A strategic project specifically for e-waste and batteries for the recovery of CRMs should be established. There should be a two-year+ support programme on implementation, to evaluated new technologies and capabilities. It is essential that there is a sustainable level playing field in the European Single Market. Suitable financial incentives should be put into place to establish CRM reserves in Europe. Collaborative regulations (e.g. as part of the draft Battery Regulation, draft Waste Shipment Regulation and through the review of the WEEE Directive etc.) should be incorporated supporting the effective capture of e-waste and batteries in Europe. We remain open to further clarifications and collaboration.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

31 Oct 2022

The European Electronics Recyclers Association (EERA) recognises there have been many advantages in the EU WEEE Directive, which aimed at ensuring the polluter pays, and that the full life cycle of a product is obligated under extended producer responsibility requirements. The following represents our continued call for change. Harmonisation: This has not been accomplished, causing conflicts within the industry and an increase in the burden of documentation, reporting and enforcement. The fact that on average only 45 percent of the WEEE is responsibly collected and treated in the EU, while the target from 2019 onwards has been 65 percent, is an indication that the policy circle is not functioning optimally. EERA calls for harmonised requirements across Member States in the form of an EU Regulation, thereby holding binding legal force to be transposed in every Member State and overruling national laws. Scope: The current divergences between the different countries create imbalanced operational conditions (e.g. Greece uses 63 sub-categories). Furthermore some producer collective schemes still operate using a combination of the previous and most recent WEEE categories, causing confusion and a lack of cohesion, especially for inter-European shipments. More emphasis should be placed on the classifications according to product content, hazards, and treatment requirements rather than size. Collection: As the collection practices are inconsistent across Europe, undocumented routes (especially illegal or less stringent export routes) will be at the forefront of the reasons why the EUs collection targets are not being met. Producers and producer collective schemes should remain responsible for all EEE they put on market, not strictly just WEEE that is available to them. EERA maintains that there should be a mandatory handover of WEEE to approved European WEEE collectors and compliant re-use and recycling operators. Proper Treatment: The WEEE Directive states: ..different national applications of the producer responsibility principle may lead to substantial disparities in the financial burden on economic operators. Having different national policies on the management of WEEE hampers the effectiveness of recycling policies. For that reason, the essential criteria should be laid down at the level of the Union and minimum standards for the treatment of WEEE should be developed. 2012/ 19/ EU (6). The fact that some MS have implemented mandatory certification of WEEE operators is positive, but the leakage across internal European borders to those countries with poorer waste management controls fosters unfair competitive advantages and discourages the stability needed for investing and maintaining existing and new innovative recycling technologies. The continued tolerance of non-compliant routes leads to the loss of critical raw materials (CRMs) and valuable secondary materials. EERA continues to press for mandatory treatment standards to be in place across Europe. Recycling and Recovery Targets: These are overly focused on weight-based metrics rather than quality focused goals that could include the recovery achievements of key CRMs and of the removal of hazardous components (e.g. batteries. Substantiated estimates provided by some MS allow inflated and uncorroborated data that also provides no evidence that correct treatment and recovery has been carried out. EERA continues to advocate that targets should be more tailored to specific product types, with more emphasis placed on other targets within the waste hierarchy beyond solely material recovery, and with recycling and re-use rates being assessed in unison. Substantiated estimates should not be permitted. We remain open to on-going collaboration.
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Response to Review: Restriction of the use of hazardous substances in electronics

9 Mar 2022

The objectives of the RoHS Directive, to reduce the use of hazardous substances in EEE, have been met and this is excellent. RoHS de-facto has become a global standard. EERA is pleased that the EU the Commission published its European Green Deal, announcing a chemicals strategy for sustainability. The Commission promised to look at how to simplify and strengthen the legal framework and review how to use the EU’s agencies and scientific bodies better to move towards ‘one substance – one assessment’. For these reasons EERA is in favour of transferring the RoHS Directive into becoming a global standard and to repeal the RoHS Directive and to incorporate the provisions into the REACH Directive, the EU Chemicals legislation.
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Response to Update of concentration limit values of persistent organic pollutants in waste

22 Nov 2021

EERA position November 2021: The policy objectives of the circular economy and the objectives of a non-toxic world can only be reached by finding an intelligent balance between the two justified interests and EERA hopes to be able to contribute to this debate with this text. . Fact is that those POP BFRs have been regulated and restricted over more than a decade and that therefore these substances are phasing out, even without changing the goalposts. The proposal to reduce the Low-POP Content threshold for those POP BFRs therefore might sound logic, but it is not. WEEE plastics account for a large volume of highly valuable tech-plastics and the EEE producing industries have pledged to take up large volumes of properly recycled Post-Consumer Recycled tech-plastics from WEEE. Therefore, the Circular Economy requires more WEEE plastics to be recycled properly and compliantly and this requires more recycling capacities in the EU. The reasons why the capacities of WEEE plastics recycling are insufficient in the EU is related to the facts that (1) most WEEE plastics left Europe undocumented until very recently (and most likely even today) and (2) the legislative landscape for the recycling of these WEEE plastics is so complex and (3) because of these POP threshold discussions that never seem to come to an end. The WEEE plastics recycling industry is new and had to learn to deal with the separation and environmentally sound management of these separated BFRs. This new industry did learn it and is now showing that in terms of the environmentally sound management of POP BFRs. This mechanical recycling route of WEEE plastics is the best possible route to make sure that these POP BFRs are separated and properly destructed by thermal processes. The Circular Economy also requires more types of WEEE plastics to be recycled from the complex mix of WEEE plastics. This is only possible through Innovations, which is linked to new technologies to separate and meet the legal thresholds of POP BFRs in recycled articles. Innovations stop when thresholds of these POP BFRs continue to be lowered, as any new technique will have to go through a learning curve. Lowering particularly the Unintentional Trace Contaminant thresholds would have devasting effects on such innovations, that are critical for the Circular Economy. A major problem with any reduction of the POP BFR threshold is related to the issue of the practical implications to the screening methods. POP BFR screening of the Low POP Content Thresholds in wastes is very complex and, in many cases, not required and in those cases in which these screenings are required, it may be expected that they are very often not performed. The screening of recycled plastic material is easier, but there are limits to the values that can reliably be measured, as the standard EN 62321-2-1 shows. This standard is validated for RoHS threshold values which are 1000 ppm for the substance group of the PBDEs. The last POP Regulation was published only in June 2019. Beyond the political will to lower threshold values for POP BFRs, EERA only sees disadvantages for the development of the Circular Economy in the EU. As the restrictions have taken place long ago, the levels of POP BFRs lower anyway, irrespective of any further lowering in LPC or UTC values. It is likely, that WEEE plastics will be driven into undocumented channels, if threshold reductions are taking place and this risks to result in adverse effects on the environment. For these reasons EERA therefore strongly recommends, that the Low POP and the Unintentional Trace Contaminants thresholds for the POP BFRs are not changed from the levels that were decided upon only two years ago and to keep the values as set in the POP Regulation 2019/1021 of June 20th, 2019. The full text is attached. Full text with annexes is available at the EERA website www.eera-recyclers.com.
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Response to Modernising the EU’s batteries legislation

28 Feb 2021

EERA welcomes the European Commission approach of the transposition of the Batteries Directive into a Batteries Regulation. The fact that the Commission recognizes and addresses highly interlinked problems related to batteries is welcome to recyclers of waste electronic and electric equipment. The lack of framework conditions and of a sufficiently level playing field, the sub-optimal functioning of recycling markets and the uneven implementation of Batteries Directive have been obstacles to functioning recycling markets and to a real circular economy. In the attachment the full feedback document. February 2021
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Response to EU rules on transboundary waste shipments – update concerning plastic wastes

16 Jul 2020

EERA is pleased with the summary of the newly worded delegated act and especially with the declared objectives: • Prohibiting the export of hazardous and hard-to-recycle plastic waste from the EU to non-OECD countries. • Setting out control procedures for the export of such waste to OECD countries. • Clarifying that intra-EU shipments of non-hazardous waste are exempt from new controls. EERA suggests, as we did in the first informal reaction, to refrain from implementing the A3210 code for deliveries of WEEE- or other complex mixes of plastics from technical products within the EU or for imports into the EU, if it is proven that environmentally safe processing of these plastics mixes is guaranteed. Classifying such wastes as hazardous would indeed unnecessarily increase the costs of notifications, transport, and incineration of the non-recyclable content without any benefits to the environment. On the contrary this would promote the illegal export of these complex wastes. The practical problem with the wording of the A3210 waste code is that it does not take the environmentally safe treatment of these wastes into account. The wording “Plastic waste, including mixtures of such wastes, containing or contaminated with Annex I constituents, to an extent that it exhibits an Annex III characteristic” leaves a lot of freedom of interpretation to the many competent authorities within the EU. Therefore, Intra-European shipments of these valuable wastes to appropriate treatment and/or recycling facilities that have the technology to properly separate plastics that contain substances of concern and properly discard these, are hindered if not stopped by classification as hazardous waste for various reasons, as we currently observe in France (HP14), the UK (threshold values) and in some German federal states (Low POP Content). In a recent court case, the EU Court of Justice judged that the most important criterium pertaining the presence of impurities (or contaminations) in a mixture of waste is whether that mixture can be recovered in an environmentally sound manner and not defined thresholds as such (C 654/18 of May 28th 2020). E-Waste plastics have in most cases been used in electronic appliances in households or offices for periods up to decades. The embedded legacy substances do not disappear or release from the plastic structure and therefore do not pose an immediate risk for either health or environment. Therefore, there is no pressing reason to classify these mixtures of plastic wastes as hazardous wastes at end-of-life. This waste material just needs to be treated properly. Post-Consumer Recycled plastics generated at these facilities must comply with product legislation (such as REACH and RoHS) and the separated plastics containing the restricted substances need to be properly discarded in appropriate thermal treatment processes. The notification process, that is linked to the new EU code EU48, allows for a thorough check of the environmentally sound management in the receiving treatment facilities. EERA, therefore, requests that the delegated act will allow all plastic mixes from the recycling of technical products such as WEEE, to be allowed to travel to environmentally sound treatment facilities within the EU under the waste code EU48 as amber waste with a procedure of prior consent (notification) and to refrain from the application of the A3210 code in such cases. In the attached document EERA also gives feed-back to the massive amount of cross-referenced documents in this text of the delegated act. Arnhem, 16 July 2020.
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Response to Update of concentration limit values of persistent organic pollutants in waste

18 Jun 2020

EERA submits its feed-back in the attached PDF file.
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Response to Ecodesign requirements for electronic displays and televisions

22 Oct 2018

The European Electronics Recyclers Association – EERA welcomes the draft regulation on laying down ecodesign requirements for electronic displays. It is encouraging to notice that a number of our recommendations that were given in the document we sent to the EC on 29 August 2017 were included e.g.: • disassembling requirements for treatment, • functional requirements that make ‘removal’ of the WEEE Directive Annex 7 materials and components possible, • correct marking of plastics and the control of it. However we also miss some important recommendations, which are not included and should be included. Especially the recommendation of not using flame retardants in displays, where they are not necessary i.e. when there are no internal heat sources. So EERA would like to see an article in Annex II D 2.2 which reflects this requirement e.g. that the use of flame retardants is not permitted in the enclosure and stand of electronic displays. The reason is that adding flame retardants to displays largely reduces the recyclability of these plastics. The benefit to utilize plastics from displays into post-consumer recycled plastics outweighs from an environmental and safety point of view by far the use of flame retardants. Another point that EERA would like to bring up is the information and documentation for repair and re-use and end-of-life, which is published on the website of the producer must be linked with a label/identification on the display itself that refers directly to the on-line information. Labels/identification with adhesives should not negatively impact the recyclability of the displays.
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