September 22, 2023

FEAD Statement on the revision of the Directive 2012/19/EU on waste electrical and electronic equipment (WEEE)

FEAD, the European Waste Management Association, welcomes the revision of the Directive 2012/19/EU on waste electrical and electronic equipment (WEEE). The revised legislation should place greater emphasis on reducing the generation of WEEE by promoting repairability and recyclability through improved product design.

FEAD supports harmonization as a key element, to eliminate disparities in waste management, enforcement, and other aspects among EU Member States, therefore, the transition from a Directive to a Regulation is necessary.

Improved collection

WEEE collection systems lack enforcement. To improve the recycling process, more collection points should be implemented and awareness among consumers should be raised. FEAD, therefore, proposes to adopt a system that can incentivise the consumer to bring the end-of-life product to dedicated points to avoid incorrect discarding that may cause health and safety problems during the waste management cycle – collection, sorting, recycling.

FEAD emphasizes the need for more robust enforcement and a stronger connection between collection systems and EEE designs that promote circularity. At the same time, collection targets should be much more differentiated, 65% is not easy to achieve from all the categories, and different approaches are needed in order to achieve different quality of recyclate.

For all these reasons, FEAD endorses the adoption of minimum collection standards to improve the quality of waste arriving to the treatment facilities. For instance, containers design in the treatment facilities should be more adapted to the types of WEEE they hold, in order reduce fire hazards, exposure to weathering and any other issues related to the presence of hazardous substances in WEEE.


As mentioned before, due to the deficiencies in the collection system, WEEE legislation needs to be strongly interlinked with obligations towards a more circular-friendly design of EEE, including features like:

  • easy battery removal
  • clear identification of hazardous materials
  • recycled content targets.

In these regards, FEAD points out the absence of guidelines for efficient resource utilization in the production of EEE and believes that obligations for using recycled materials should be implemented.

Moreover, FEAD supports the development of a digital product passport to facilitate communication between producers and recyclers, with an emphasis on design for recycling obligations.

Phased recycling targets and recycled content in EEE

Recycling targets should not merely focus on percentages, but also consider the quality and type of materials to be recycled.

Recycling rates should be more flexible, in order to accommodate changes in EEE composition and in the lists of hazardous substances. According to this, FEAD suggests setting targets for specific substances like critical raw materials and precious metals to support the sustainability of the recycling industry.

Moreover, plastics used in WEEE may contain some hazardous substances (or substances of concern). Restrictions on these substances are increasing and they should be excluded from the weight of the waste that accounts for the recycling rate calculation. FEAD believes that the recycling rate cannot be calculated on the total amount of plastics in WEEE, but only on the mass of plastics that do not contain hazardous substances (or substances of concern).

FEAD proposes, alongside the introduction of quality-oriented criteria, the implementation of progressive phased-approach of minimum recycled content targets and recycling targets as a promising added value to foster the achievement of the mentioned targets.

Polluter Pays Principle and Extended Producer Responsibility

FEAD calls for more efficient collection systems financed by producers, including online retailers and advocates for the implementation of tailored eco-modulated fees. Equally, producers should contribute to the setting up of fire protection measures in waste management facilities in view of the number of fires and associated costs we are suffering, due to lithium battery-related fire incidents in our facilities.

In addition, FEAD advocates for the implementation of a Deposit Refund Scheme (DRS) to further incentivise the return of batteries and the achievement of the collection target. The system should be applied to all WEEE containing batteries, especially where these are difficult or impossible to remove, such as in childrens’ toys and small WEEE. FEAD believes that the Commission could evaluate this specific proposal in conjunction and in line with the assessment report referred to Article 63 of Battery Regulation 2023/1542.

Environmentally sound management of WEEE

The management of WEEE should exclusively be on permitted operators to ensure proper treatment. Adequate treatment capacity, implementation of recycled content targets, and simplification of waste shipments within Europe will contribute on retaining WEEE within the EU.

At the same time, illegal shipments of WEEE falsely declared as used/second-hand goods must be tackled. Clearer guidelines concerning the shipment of components and fractions resulting from WEEE treatment, alongside stronger control and enforcement measures are needed.

A holistic approach to circular economy

To conclude, FEAD stresses the importance of aligning the revised rules for WEEE with other relevant EU legislation, such as the Waste Shipment Regulation, Eco-design Directive, RoHS Directive, Batteries Regulation, and CRMs Regulation.

FEAD calls for a comprehensive and harmonised approach to WEEE management, focusing on product design, efficient resource use using recycled content, improved collection, recycling rates, eco-modulation of EPR fees, enforceability, and alignment with broader EU legislation to foster a circular economy.

FEAD Secretariat

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fuelling €5 billion of investments into the economy every year. For more information, please contact: