WEEE Forum aisbl
WEEE Forum
The WEEE Forum, set up in 2002, is a Brussels-based international for-impact, not-for-profit association speaking for fifty-one not-for-profit electrical and electronic equipment waste (WEEE) producer responsibility organisations (PRO) that take back and manage WEEE, as defined by Directive 2012/19/EU, from households and businesses.
ID: 702397445-73
Lobbying Activity
Meeting with Wouter Coussens (Cabinet of Commissioner Piotr Serafin)
21 Jan 2026 · Own resource on e-waste
Meeting with Jeannette Baljeu (Member of the European Parliament)
5 Nov 2025 · Circular Economy Act
Meeting with Rasmus Nordqvist (Member of the European Parliament)
5 Nov 2025 · Circular Economy Act
Response to Circular Economy Act
4 Nov 2025
The WEEE Forum are supportive of initiatives that create a fully integrated, efficient, fair and resilient circular economy, securing the supply of critical raw materials, stimulating investment, and supporting long-term environmental, economic, and strategic benchmarks. A true circular economy calls for a robust legal framework centered on inclusive responsibility, clear regulations, coordinated enforcement, and broad societal engagement.
Read full responseResponse to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252
18 Jul 2025
Download the file to explore the WEEE Forum's comments on the proposed Implementing Regulation.
Read full responseMeeting with César Luena (Member of the European Parliament)
12 May 2025 · Circular Economy
Response to European Critical Raw Materials Act
24 Nov 2022
Secondary materials, especially materials such as rare earth elements, gallium and indium, that are needed in renewable energy technologies or high-tech applications, make a marginal contribution to meeting materials demand. The WEEE Forum will consider involvement in projects and support for legislative and non-legislative initiatives that seek to promote better collection of WEEE in order to maximise recovery of critical raw materials.
Read full responseResponse to Evaluation of the 2012 Directive on waste from electrical and electronic equipment
3 Nov 2022
In Europe, unlike in the rest of the world, the rate of growth of volume of WEEE that is properly treated and recycled exceeds the rate of growth of the volume of WEEE that is generated. The WEEE that is collected is also treated to higher standards than in the rest of the world. Thats largely thanks to twenty years of Extended Producer Responsibility legislation across Europe. However, legislation must be redesigned to make it fit for purpose for new market realities. The WEEE Forum will contribute constructively to a thorough evaluation of WEEE legislation with a view to improving its effectiveness, efficiency, relevance and added value. This is our response to the Call for Evidence.
Read full responseResponse to Fitness Check of EU consumer law on digital fairness
24 May 2022
Online platforms that are consumer facing are a part of the everyday life of consumers and professional customers shopping for products and services online. They include traditional marketplace services and social media networks. Whilst these services can improve consumer and business choice, they also open a backdoor for traders who do not play by the EU rules.
Read full response11 Apr 2022
Installations of photovoltaic panels (PVs) have rapidly increased. In 2019, the newly installed solar power in the EU increased by 11%; in 2020, an 11% improvement with respect to 2019 (SolarPower Europe, 2020). Considering a lifetime of 20-25 years, data indicate that there will be a boom in waste PVs towards the end of this decade.
PVs contain recoverable materials such as Al, Pb, Cu, Zn, Fe, Ag, glass, steel and plastic and critical raw materials such as In and Ga. PVs must be treated in regulated treatment facilities that ensure proper depollution, and recovery of secondary and critical raw materials. It is of utmost importance that the management of all PVs put on the market count with the appropriate financing, reporting and treatment schemes. Our experience in the sector tells us that permitting is an excellent instrument to enforce compliance with obligations of the Directive.
PVs are in the scope of Directive 2012/19/EU on WEEE based on the extended producer responsibility principle (EPR); producers include manufacturers, importers, retailers that are required to register, report sales and waste PVs collected, and cover financial needs to manage end-of-life equipment. Producers have set in most Member States Producer Responsibility Organisations (PROs) to deal with obligations arising from legislation
In most Member States, there are PV panel producers who do not comply with their EPR responsibilities. They free-ride, i.e. they create an unfair competition by evading costs and administrative burden for compliant companies and distort statistics on reported volumes.
To tackle the free-riding issue we call on policymakers to:
1. Condition the licensing procedure of grid connections/solar fields to WEEE compliance; to be granted permission, permit applicants should prove that the PVs installed come from a compliant PVs producer i.e. registered on the national WEEE register and has either contracted a PRO dealing with PVs or set an individual scheme as per article 12.3 of the Directive.
2. In case a producer chooses to fulfil their EPR obligations individually, and considering the long life of PVs, additional proof should be required showing that there is an appropriate financial instrument ensuring enough funds are available to finance the management of the PVs once they become waste.
3. Introduce an obligatory PV panel tracking system on PVs installed in solar fields to avoid their ‘disappearance’ through illegal routes. This is to be included as a condition for obtaining the permit to connect to the grid or the permit of the solar field.
4. Require an end-of-life plan along with the grid license application. The plan will describe how end of life PVs will be managed and provide evidence of the measures set in place (e.g. contracts with recycling facilities, PROs etc.)
5. Make WEEE compliance a requirement for accessing grants and subsidies offered for the implementation of any professional solar panel installations.
Other measures to consider are:
6. Agencies accrediting installers of PVs should require them to provide evidence that all PVs supplied come from registered producers.
7. Online marketplaces selling PVs should be held responsible for checking that their merchants are registered and provide evidence that installers can use for their permitting procedures.
Permitting is an excellent instrument for countering freeriding, which is a relevant problem that must be addressed urgently. We often see a lack of alignment and support between EU legislations, which hinders compliance and enforcement. Measures suggested in this document will allow different pieces of legislation to align and support circular economy.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
27 Jan 2022
Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE) (hereinafter “the Directive”) says that from 2019, the minimum collection rate to be achieved annually shall be 65%(1) of the average weight of electrical and electronic equipment placed on the market in the three preceding years in the Member State concerned, or alternatively 85% of WEEE Generated (WG) on the territory of that Member State. Member States were charged with the responsibility of reaching WEEE collection targets and, based on the polluter pays principle and the Extended Producer Responsibility (EPR) principle, producers of electronics were required to finance the collection, recycling, recovery and sound disposal of the WEEE deposited at collection facilities, amongst other things. Enormous progress has been made during this time – according to Eurostat, 48 million tonnes of WEEE have been collected in the European Union between 2005 and 2018 – and from a legislative point of view all Member States have implemented specific WEEE regulations and have mechanisms to address the requirements of the Directive. However, after so many years of concerted effort, most Member States are unable to reach the 2019 collection targets. In those 17 years, producers and producer responsibility organizations (PRO), and other actors in the WEEE value chain, have invested a significant amount of effort to better understand and share best practices on target attainment, and why reaching the increased collection targets has proved difficult. Numerous studies mapping the destination of WEEE and existing flows have allowed PROs to understand where the unreported WEEE may be going. However, the evidence presented in those studies lead to the conclusion that most undocumented WEEE flows will not be reported and cannot be robustly estimated unless all actors having access to the WEEE have reporting obligations. See the WEEE Forum's vision on EPR and the role of all actors, and the UNITAR report. https://weee-forum.org/wp-content/uploads/2020/11/EPR-and-the-role-of-all-actors_final.pdf (file attached); https://weee-forum.org/wp-content/uploads/2020/11/In-depth-review_WEEE-Collection-Targets-and-Rates_UNITAR_2020_Final.pdf (>5 MB)
Read full responseResponse to Update of concentration limit values of persistent organic pollutants in waste
30 Jul 2020
Waste of electrical and electronic appliances (WEEE) and plastics thereof are subject to many regulations dealing with e.g. WEEE, waste, persistent organic pollutants etc., and indirectly affected by other product- related legislation, such as rules on eco-design, restriction and control of hazardous substances, etc.
We encourage the European Commission to assess the impact of lowering POP limit values as regards compliance with the above mentioned legislation, and in particular with the attainment of the recycling and recovery targets set by the WEEE Directive (2012/19/EC) in its Annex V.
Currently, official treatment processes are already dealing with the sorting of plastics containing restricted brominated flame retardants (BFRs) of which PBDEs. It should be noted that very low limits (like the ones suggested for Low POP Content in the revision of the POP regulation) will add complexity to already existing complex testing procedures, therefore such a change will only be acceptable if it entails a relevant improvement of the situation. Plastic recyclers are currently testing the plastics resulting from their processes in which the limit applicable is 500 ppm and carrying out tests at this step is more practical and easier. We wonder about the benefits of measuring 500 ppm at the end of the WEEE recycling process (i.e. before the processing of the plastics in a dedicated facility that will ensure removal of plastics containing restricted BFRs). The current Low POP Content threshold of 1000ppm is already serving its purpose which is to identify and force the sorting of BFRs containing plastics. Measuring 1000 ppm is easy and good enough for this purpose.
We can see a mismatch between the proposed changes in the legislation and the goals the POP regulation is aiming at.
We suspect that a change in the Low POP Content threshold from 1000 ppm to 500 ppm will barely change the current processes in place and will simply implement more complex testing procedures. The applicable threshold for Unintended Trace Contaminants of 500 ppm should ensure already that plastics introduced into new products meet the POP limit values.
We strongly recommend to access the impact of the reduction of the Low POP Content threshold:
1. in the current practices and processes of the industry; and
2. the final content of POPs in the recycled plastics available for manufacturing of new products.
The assessment should evaluate if the changes derived from the reduction of the threshold will be meaningful from an environmental point of view compared to the existing situation and levelled with the efforts and resources required for implementing the change.
At present, the recycling industry, and in particular the plastics recycling industry, is very much needed in Europe for helping us achieve the circular economy targets and face the challenges derived from the recent changes in the global market. We believe that legislation must work towards a safe and environmentally viable management of resources and at the same time facilitate the processes and factors required for this to happen.
Read full responseResponse to A new Circular Economy Action Plan
9 Jan 2020
As grounds for EU intervention, the Commission Communication (Roadmap) says: "Regarding waste management, an explicit mandate in the new EU waste legislation requires a review of existing law as well as considering additional measures for new waste streams. This will ensure legal certainty for economic operators, allowing smooth functioning of the internal market and a level-playing field in terms of environmental protection and resource efficiency." The WEEE Forum are supportive of this approach. As regards WEEE (waste electronic and electrical equipment), the Commission is considering the preparation of possible Implementing Acts laying down minimum quality standards for treatment of WEEE. The WEEE Forum in coalition with the other main stakeholders in the sector strongly believe that, in preparing those Implementing Acts, the Member States and the European Commission must acknowledge the importance of strictly implementing all requirements from EN 50625 and EN 50614, the suite of CENELEC standards covering the collection, transport, re-use and treatment of WEEE, and avoid their watering down since they represent one integral set of standards to be applied by all actors in a harmonised way throughout Europe for improved quality waste management.
Read full responseMeeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)
7 Feb 2019 · WEEE Waste Manangement
Response to Methodology for the calculation of the weight of EEE placed on the market and of WEEE generated
3 Jan 2017
CECED and the WEEE Forum welcome the opportunity of the public online consultation to provide comments on the new version of the draft implementing regulation and annexes. CECED and the WEEE Forum already provided DG Environment with some comments and amendment proposals in June 2015 and would like to reiterate some of them.
DEFINITION OF WEIGHT OF EEE (ARTICLE 2). We believe that the Commission Implementing Regulation should clarify that the definitions provided in Article 2 apply to both household and professional EEE.
CALCULATION OF THE WEIGHT OF EEE PLACED ON THE MARKET OF A MEMBER STATE (ARTICLE 3). We welcome the changes made by the Commission compared to the 2015 draft version. It is important that quantities are counted based on real, accurate and sound data as reported by EEE manufacturers to national registers. Only in case available data is not considered accurate enough, should Member States have the option to estimate the quantities of EEE placed on the national market using the methodology set out in Annex I.
Ideally, Member States should notify the European Commission about their choice of calculation methodology, i.e. based on national registered data or estimates in accordance with the methodology set out in Annex I. When a Member State opts to use “the methodology”, appropriate justification should be provided to the Commission in the form of surveys, audit results or consultation with relevant stakeholders.
Regardless of the method used to calculate the weight of EEE placed on the market at national level, Member States should make their choice publicly available, together with the collection targets in case Member States opt to calculate them based on the quantities of EEE put on the market (POM).
CALCULATION OF THE TOTAL QUANTITY OF WEEE GENERATED IN A MEMBER STATE (ARTICLE 4 AND ANNEX II). We very much appreciate the changes brought into the wording of the discard-based lifespan profile for the batch of EEE placed on the market in year ( ). The use of the wording “discard rate” is more suitable than the 2015 wording proposal.
Making both the electronic tool and the lifespan data sitting in the electronic tool available to relevant stakeholders is key to ensuring accuracy of the data and alignment with estimated calculations. CECED and the WEEE Forum would welcome the feasibility of setting a period or a demonstration for stakeholders and experts to test and evaluate the electronic tool.
It is key that lifespan data at national level are frequently revised to ensure that lifespan profiles embedded within the electronic tool reflect the real technology and socio-economic developments within the Member State.
We find it positive that the European Commission added point 5 in Annex II (methodology for the calculation of the total quantity of WEEE Generated in a Member State): “Before proceeding with such updates, Member States shall inform the Commission thereof and shall provide relevant evidence for such updates, including official market surveys, audit results or analysed and substantiated data resulting from consultation of relevant stakeholders”.
It is a clear improvement and gives a clear message for transparency of the process at Member State level and the need for evidence backing the changes prior to the update. This could be further improved by making the lifespan data and profiles publicly available. We appreciate that the collaboration of national authorities and relevant stakeholders at national level is crucial on this dossier, as this can only improve data quality.
In addition, Annex II of the draft Implementing Regulation says: “In the tool, data of EEE placed on the market from 1980 up to 2012 and product lifespan for the period 1980-2030 have already been provided.” To ensure transparency, data should be made publicly available.
Read full response