FEAD’s key messages for the revision of the WEEE Directive under the CEA

FEAD welcomes the Commission’s intention to modernise the Waste Electrical and Electronic Equipment Directive within the Circular Economy Act. FEAD also welcomes the intention to turn the WEEE Directive in a Regulation, as the various interpretations of the current framework result in different obligations and conditions in each Member State, contributing to an uneven playing field in a variety of points (e.g. competition faced between operators, severity of enforcement, waste categories, registration requirements, storage and collection methods etc.).

Additionally, Europe’s current system still under-collects WEEE, loses valuable critical raw materials (CRM) and does not achieve true circularity. A revised WEEE framework should deliver three outcomes:

1. substantially higher, safer, and more convenient collection.
2. efficient and economically viable recovery of materials, including CRMs.
3. fair, transparent, and fully cost-covering extended producer responsibility that rewards performance while closing enforcement gaps.

Ensuring circularity of WEEE

The value of materials in WEEE is continuously decreasing due to the reduced use of metals and the increased use of lower-cost materials, such as plastics, in EEE. This affects the ways in which recycled materials can be used and thus the economic viability of recycling.

FEAD’s proposals for boosting the demand[1] for recycled materials under the Circular Economy Act remain valid, especially regarding recycled content definitions, the prioritisation of European recyclates, the implementation of new recycled content obligations for plastics, green public procurement and the use of eco-modulation to incentivise the uptake of recyclates in new products.

To ensure a stable and growing circular economy for the WEEE sector, FEAD proposes:

• Creating EU market demand for recycled materials from WEEE by imposing recycled content targets for materials present in EEE, such as plastics and some CRM.
• Increasing recyclability via ecodesign, ensuring each type of EEE placed on the market can be recycled at scale, and to enable the recovery of as many materials as possible. In the case of EEE, ecodesign should also address the issue of limiting the use of substances of concern and facilitating the recovery of CRM (see below).
• Ambitious but realistic recycling and recovery targets, tailored to each WEEE category.
• Efficient EPR schemes to finance the system and encourage good practice that goes beyond the regulatory minimum in terms of ecodesign and recycled content. More complete proposal can be found in the part ‘Making EPR for WEEE fit for purpose’.  

Raising collection in practice

Targets and calculation methodology. Ambitious targets remain important to drive performance. Any revision of the calculation method must not lead—de facto—to lower ambition e.g. the absolute quantity of WEEE to be collected according to the target must remain the same or be increased.

FEAD proposes a series of approaches to increase the collection of WEEE, beginning with the densification of collection networks to make the WEEE collection a seamless experience for consumers:

• Obligations for online sellers. With online retail steadily growing, FEAD considers it very important to require online sellers—including those based outside the EU—to provide free take-back at delivery (reverse logistics) and to co-finance dense, producer-funded collection networks close to households and SMEs. Proper enforcement across all Member States and strict controls for all actors placing EEE on the market are essential.
• Retailer obligations irrespective of point of purchase. Sellers should accept WEEE regardless of where the product was originally purchased (0-for-1 take back), to expand the density and clarity of drop-off options and align with consumer behaviour.
• Deposit-return systems (DRS) for batteries and embedded devices. DRS for WEEE should be assessed case-by-case, based on environmental outcomes, territorial context, and market impacts. FEAD sees strong potential for DRS on lithium batteries and battery-embedded devices, as these wastes are often misplaced in wrong waste streams and source of numerous fires in the waste management sector[2].
• Minimum standard requirements for collection sites should be defined to facilitate collection (including, for example, minimum operating hours and opening to all citizens) and improve the quality of the waste arriving at the plants.

Public awareness and convenient access. Sustained, product-specific national campaigns are very important to raise returns in low-performing categories and to address fire risks from embedded batteries. Campaigns should be targeted and co-financed by PROs, as well as being practical and convenient.

Tackling illegal exports and misclassification. Illegal exports drain Europe’s collection base and depress investment. FEAD calls for:

1. EU-level minimum requirements for equipment exported for re-use outside the EU, to prevent WEEE being shipped as EEE when it should be recycled.
2. Reinforced border controls and equivalent treatment conditions for non-EU facilities.
3. EU guidelines to harmonise classification practices so customs and port authorities consistently distinguish WEEE from scrap and used EEE.

Data, registration, and reporting. Effective oversight requires visibility on flows without unnecessary administrative burden. FEAD supports national-level, harmonised data collection with a single data collection point, in alignment with well-functioning existing reporting practices. WEEE management should be performed by approved collectors contracted with producers/PROs and following WEEE treatment standards. Any shift to unified reporting must avoid duplicative obligations for operators and must not destabilise performing national setups.

Unlocking material and CRM recovery from WEEE

The main impediments to material recovery from WEEE are insufficient demand, low concentrations and dispersal of CRMs across devices, and uncompetitive economics vis-à-vis virgin supply. While recovery is technically feasible for certain CRMs, it often requires complex and costly dismantling and separation processes to extract very small quantities from mixed fractions.

Information and design for disassembly. Recyclers lack reliable, actionable information on CRM content and location in WEEE. Additionally, EEE are poorly designed for disassembly and efficient recycling. Ecodesign requirements must facilitate identification, removal, and safe extraction of components, as well as overall recyclability of the appliance. Ecomodulation should reward design that eases recovery, recyclability and the use of recycled materials, including of CRM. The Digital Product Passport (DPP)[3] could be one of the tools to increase transparency and efficiency in the CRM recovery value chain, for example by giving recyclers the quantities, where-to-find, and dismantling procedures. The DPP implementation and data-access costs (including readers at recyclers’ facilities) should be shared with EPR schemes.

Price signals and operating costs. Low prices of primary materials, high costs of recycling due to dispersed quantities, and high cost of energy in the EU all disadvantage recycling, both for CRM and other materials such as plastic. WEEE EPR schemes should provide financial support for downstream recycling infrastructures to identify, sort and extract recyclable materials, including CRM, to make recycled materials more competitive. Furthermore, FEAD urges the Commission to ensure that energy cost relief and industrial policy tools also reach sorters and recyclers, who often do not qualify for current energy-intensive industry schemes yet face relatively higher energy costs than primary producers.

Infrastructure and refining capacity. Europe lacks sufficient refining capacity because the business case for recycled CRMs is weak. EU facilities struggle to compete with third countries, where refining infrastructure benefits from lower costs and more favourable economic conditions. As demand for recycled CRMs grows, investment in EU infrastructure will follow — but only if the economic conditions improve. The CEA should therefore aim to align recycled materials supply with EU industrial capacity to use recycled CRMs, avoiding mismatches between available resources and end-users.

Refrain from imposing trade restriction. Export restriction measures applying only to recycled materials, while leaving primary raw materials unaffected, risk placing European recyclers at a competitive disadvantage and undermining the level playing field needed to support a circular economy.

Innovation and technology readiness. Continuous innovation must be supported, particularly for advanced separation and for CRM recovery and purification where EU capacity is still limited, including for permanent magnets. The issue is not the lack of technology, but rather the need for innovation to keep pace with rapid changes in product design and complexity.

Standardised treatment. Standard EN 50625, which sets out the requirements for the collection, logistics and treatment of WEEE, or equivalent national standard[4], should be mandatory for all operators handling WEEE. This would contribute to ensure that all types of operators contribute equally and within high-quality standards to WEEE collection and treatment, creating a level playing field. The costs of certification must be borne by extended producer responsibility schemes, as they may be disproportionate, particularly for SMEs. Furthermore, recyclers must be involved in the future developments of these standards.

Optimising WEEE categories

Targeted category reform can improve logistics, safety, and CRM recovery:

• Photovoltaic (PV) panels: Create a dedicated category. PVs do not fit current category 4; lifespan, composition, and treatment routes justify specialist handling and dedicated facilities.
• Digital and telecom equipment: Replace the size-based split with a single IT/telecom category under category 6, regardless of dimensions. Treating large server cabinets like washing machines is illogical; grouping all IT/telecom devices together will better support CRM and precious metal recovery.
• Battery-powered equipment: New subcategories should be introduced for battery-powered appliances, in order to better control the fire risks and ensure proper treatment of such appliances. This should be paired with increased producers’ responsibilities, covering higher collection costs and better awareness.
• Keep equipment comparable to infrastructure (e.g. wind turbines, large electricity and telecommunication cables) out of the scope, as these waste streams are already being managed appropriately within existing waste management systems. Additionally, WEEE treatment facilities do not always have the necessary equipment.

Making EPR for WEEE fit for purpose

FEAD has a comprehensive position on EPR schemes[5] that still applies for WEEE stream, notably regarding the participation of waste management operators in national independent advisory and monitoring bodies.

Producer responsibility and target compliance. FEAD supports keeping producers legally responsible for meeting national WEEE collection targets and for the externalities of uncollected and mismanaged WEEE. Producer responsibility must go beyond hitting a numeric target: even when targets are met, producers remain responsible for WEEE left in informal channels, or causing environmental and operational damage (e.g., battery fires). Penalties for non-compliance should be clearly defined, strictly and promptly enforced, and embedded in a harmonised EPR framework so they do not trigger artificial cross-border “target chasing.”

What WEEE EPR should finance. Beyond collection-to-recycling, EPR should cover final treatment and additional depollution costs associated with the presence of substances of concern in WEEE; targeted awareness campaigns; compositional surveys (including mixed municipal waste and other likely WEEE-bearing streams like CDW and residual industrial waste); data gathering and reporting; and should co-finance recycling infrastructures upgrades to identify, sort, dismantle, and recover materials from WEEE. For EEE with embedded batteries, EPR must contribute to fire prevention and mitigation (detection and suppression systems, insurance, emergency response, and facility recovery).

B2B vs B2C. FEAD supports keeping B2B and B2C EPR schemes distinct. Markets, product characteristics and logistics differ substantially and should be reflected in organisation and fee structures. Ambition levels can converge, but a forced one-size-fits-all model would be counterproductive. Mandatory take-back system at the cost of the waste producer for BtoB WEEE should be implemented, as it is currently the case under Article 5 of the WEEE Directive for WEEE from private households. 

[1] https://fead.be/wp-content/uploads/2026/08/20260828-FEAD-key-recommendations-for-demand-CEA.pdf

[2] https://fead.be/wp-content/uploads/2025/05/Battery-Fires-in-Waste-Management_-Joint-Paper.pdf

[3] Please find more information on FEAD’s position on the implementation of the Digital Product Passport here: 20250701_FEAD_Digital-Product-Passport_Public-Consultation.pdf

[4] In some countries and for certain types of treatment, EN 50625 appears to be outdated: national standards derived from EN 50625 may be more relevant. This can be the case for heat exchange equipment treatment, where emission limits permitted in EN 50625 did not adapt to technological developments, while some nationally derived standard, which can adapt more quickly, have addressed this issue.

[5] https://fead.be/wp-content/uploads/2026/09/20260901-FEAD-key-points-EPR.pdf

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be