On February 8th 2016, the draft standard prEN 50614 ‘Requirements for the preparation for re-use of waste electrical and electronic equipment’ was circulated to National Standardisation Bodies for a first round of commenting. prEN 50614 was developed by CLC/TC 111x ‘Environment’ as a response to the European Commission’s M/518 Mandate, requiring European Standardisation Organisations to develop European standards for the treatment, including recovery, recycling and preparing for reuse, of waste electrical and electronic equipment (WEEE). In parallel, Technical Specifications for the collection and logistics of WEEE are also being developed in CLC/TC 111x.
As ECOS underlined in a joint letter the treatment requirements for WEEE laid down in the EN 50625 standard series requirements should be taken into account when initiating or revising related national legislation. This is to avoid national requirements diverging from the requirements set at European level under a given standardisation request (M/518).
Nevertheless, before compliance with such European requirements can be requested from the EC (e.g via a direct reference in the WEEE legislation), the proposed collection and logistics framework should first be improved in a way that does not discriminate against the preparing for re-use sector or that does not put the sector at a disadvantage. Indeed, an appropriate, solid and supportive collection and logistics framework for WEEE is essential to safeguard the re-use potential of the said WEEE. However, because such framework is developed in a separate working group, the collection and logistics framework may not be improved as part of prEN 50164, which may lead to less preparing for re-use, and less job creation potential.
ECOS supports laying down clear and useful requirements for the preparing for re-use of WEEE, but has raised concerns related to the current draft prEN 50614:
- ‘Preparing for re-use’ operators will face difficulties in achieving all requirements of this standard (prEN 50614) or increase their activity if collection and logistics systems (TS 50625) are not improved and if they cannot access manufacturers’ information/tools free of charge;
- The standard prEN 50614 is currently worded in a detailed and complex way, which although appreciated by an auditor, will create considerable administrative burdens for ‘preparing for re-use’ operators without any benefits for the quality of the process or for the end-user of the appliance;
- Some of the technical aspects in the standard may breach regional or national standards and/or legislation in place, especially concerning the storage of WEEE and warranty periods.
Given that preparing for re-use of WEEE can significantly increase local jobs in Europe and the engagement from social enterprises, it is crucial that this standard helps assist and support the development of re-use activities – not impede them. Moreover, legitimate preparing for re-use activities are at different stages of development and progress across Europe, a reality which this standard must take into account.
ECOS looks forward to fruitful discussions within CLC/TC 111x to overcome these challenges and continue boosting the preparing for re-use market. Preparing for re-use is a crucial aspect that can support a true circular economy in the EU today.