WEEELABEX

The WEEE Forum (www.weee-forum.org) is a European association of 39 electrical and electronic equipment waste (WEEE) collection and recovery systems. Our mission is to provide for a platform for co-operation and exchange of best practices among its producer responsibility organisations. This collaboration optimises the cost-effectiveness of the operations of the member organisations, while striving for excellence and continuous improvement in environmental performance.

The WEEE Forum also seeks to be a centre of competence that allows members to make constructive contributions to the general debate on electrical and electronic waste policy matters.

WEEELABEX stands for “WEEE Label of Excellence”. It is the acronym for a project, run by the WEEE Forum in co-operation with stakeholders from industry, with recyclers and academia, and with environmental groups. The project aims to design a set of European standards with respect to the collection, sorting, storage, transportation, treatment and disposal of all kinds of WEEE. The project is co-financed by the European Community under the LIFE programme (see http://ec.europa.eu/environment/life/index.htm). A CD ROM with the project proposal as submitted with the European Commission is available upon request.

WEEELABEX aims at addressing a number of concerns and emerging realities:

• Directive 2002/96/EC on WEEE was supposed to harmonise regulatory requirements with respect to the responsibilities for collection, recycling and recovery of e-waste in Europe, but reality is that the requirements laid down in the Directive are interpreted and applied differently across Europe. A patchwork quilt of little or no requirements alongside requirements that differ substantially from member state to member state makes economies of scale for processing companies difficult.
• As a result, the WEEE playing field is not level, i.e. treatment practices differ considerably and therefore create unfair competition among companies. In some parts of Europe, post-shredder technologies are cutting edge, while in others there is practically no experience at all.
• Consumers and electronics producers paying for the management of WEEE have no assurance of the environmental performance of companies involved in collection, transport, pre-treatment (de-pollution), treatment, and recovery and recycling.
• The electrical and electronic equipment technologies undergo a rapid development process and emerging types of equipment, such as mercury-containing flat panel displays and mercury-containing gas discharge lamps, demand new treatment solutions.
• Due to the fact that some member states fail to secure proper enforcement of their WEEE legislation, some processing companies succeed in gaining a competitive advantage thanks to the application of less environmentally sustainable activities.

WEEELABEX will make environmental performance more transparent and will level the playing field through the creation of a single, harmonised set of standards, while obviously not holding back parties that wish to go beyond those standards. It will create incentives for operators to meet the highest standards, and disincentives for dishonest companies to dodge “the system”. Operators that have not been awarded a label due to failure to comply with the standards will be subject to easier scrutiny by the authorities. WEEELABEX standards, as opposed to the legislative requirement laid down in Annex II of the Directive, allow for a more flexible toolbox; laws and decrees are too inflexible as tools to address this constantly changing landscape.

Less pollution and a cleaner environment are the ultimate objectives. The collection, sorting, storage, transportation, de-pollution and thermal/landfill disposal of all kinds of WEEE today should be improved to prevent minimise pollution and maximise the recovery and recycling of secondary raw materials.

The WEEE Forum and its 39 member organisations are committed to this superior objective.

Globally, and in Europe in particular, there exist many different types of standards, certification programmes, marking, labels and so forth. In order to avoid misunderstandings, a clarification about the project’s scope is therefore due.

• The project concerns all steps in the chain, including collection and preparation for re-use.
• The requirements related to collection activities shall be implemented, to the extent possible, by the WEEE collection and recovery organisations. They shall be designed to encourage collection facilities to play their important role in the WEEE stream.
• Operators processing WEEE that are subject to the standard will undergo third party certification. That means that first party certification, or self-declaration, will not suffice as means to demonstrate compliance with the standard. A third party, i.e. financially and materially independent from the operator, is the only guarantee for a thorough compliance check.
• The requirements laid down in the standard are minimum requirements. Producers and their collection and recovery organisations are free to stipulate requirements that go beyond the standard’s requirements, certainly if they are environmentally more ambitious.
• The WEEELABEX label or quality mark is solely aimed at sites of operators. In other words, the label will not be awarded to companies as such, but to the facilities where activities take place. Plus, it is not our ambition to produce labels for products, nor for WEEE collection, recovery or re-use organisations.
• WEEE collection organisations will have to be in a position to demonstrate that they have contracted with certified partners and that the contracts are compliant with the standard.
• Certification may initially be carried out by one Certification Company, but in time by accredited certification bodies. The WEEE Forum will not be one of them.
• Auditors performing audits in view of certification will be trained in accordance with the standard and will join a pool of auditors.

The cost of the project’s Actions has been estimated at €1,064,600. The European Community, under Life+, a financing instrument that promotes, amongst other things, environmental governance, has agreed to finance 50 per cent of the total eligible budget, i.e. €532,300. The total budget is not necessarily split in equal one-year budgets; depending on the upcoming workload, more or less money will be earmarked to specific sub-projects.

The project was approved on 28 July 2008 by the so-called “Life Committee”, an EU body composed of member states and chaired by the European Commission. After five months of pre-project preparations, the project took a swift start on 1 January 2009. EU financing of the project is supposed to end on 31 December 2012.

Early 2013, the WEEE Forum will, in co-operation with its main stakeholders, assess the appropriateness of continuing the project in some of its aspects including constitutive elements of the project, and certification.

Today, most processing companies play by the rules and meet existing standards or regulatory requirements. However, they often tend to face fierce competition from companies that apply sub-optimal specifications, or, worse, are engaged in semi-legal business. In the long run, the “WEEE Label of Excellence” will create a visible distinction between those operators that (already) meet the highest standards and those that do not.

Market surveillance, compliance monitoring and enforcement of legal requirements are typically tasks performed by authorities. However, there are a number of reasons why they are likely to welcome this initiative:

• The enforcement agencies’ resources are limited.
• Enforcement agencies are insufficiently familiar with WEEE treatment technologies.
• The regulatory agencies tend to be mainly concerned with issues of compliance with formal requirements rather than with real-life business.

In addition, the state of enforcement of the laws transposing the Directive varies from member state to member state. WEEELABEX is therefore a unique opportunity to harmonise this very important task at European level.

A harmonised set of standards will:

• Lead to economies of scale and therefore allow operators in the WEEE processing industry to reduce costs, which will benefit producers and consumers.
• Lead to less confusion among producers as to what is required to comply with legislation.
• Allow producers to position themselves as parties that take corporate responsibility seriously.

The project affects the following parties:

• The 39 collection and recovery organisations that make up the WEEE Forum are committed to implementing the standards and validation process.
• Non-WEEE Forum compliance schemes and individual producers of electronic and electrical equipment that have opted to set up brand-specific take-back solutions, so-called “individual systems” or non-market share based approaches.
• Electronic waste processing companies that provide services to the collection organisations.
• Collection facilities, for example retail and municipalities.
• European, national and sub-national legislative authorities and decision-making institutions, as well as inspectorates and enforcement agencies.
• The certification bodies, responsible for the issuance of WEEELABEX certificates.
• Manufacturing industry and entities representing producers involved in legal compliance issues.
• Environmental and consumer (non-governmental) organisations.
• Auditors in charge of the actual assessment and enforcement of the label.

Today, a number of representatives of these stakeholders have taken up a permanent seat in the WEEELABEX Stakeholders Group, a body discussing the project’s basic principles and methodology.

At first the WEEELABEX office, and later the accredited certification bodies, will issue certificates testifying that a particular site of an operator fulfils the requirements laid down in the WEEELABEX standard. It will demonstrate that the operator’s facilities have been verified by auditors under the WEEELABEX certification guidelines. The project has to create the certificate.

Certification will be voluntary and the project does not aim at turning the certification programme into a mandatory requirement, i.e. required by law. Member organisations of the WEEE Forum are, however, committed to implementing the standards and to respecting all rules and obligations laid down within the context of the WEEELABEX project.

The task of an e-waste processing company is de-pollution, pre-treatment, recycling, recovery and disposal of WEEE in compliance with legislation and “state of the art” processing. So the quality of the outcome should not be taken for granted; it has to be monitored meticulously and consistently. Targets and standards are meaningless if they are not regularly monitored.

Monitoring is indeed a task typically performed by public authorities. The trouble is that the resources of the enforcement agencies are limited. In addition, environment protection agencies may not be familiar with WEEE treatment technologies and are concerned with formal requirements and often with many other types of environmental problems. In addition, the state of enforcement of the nationally transposed Directive varies from member state to member state. In some states, authorities have delegated the monitoring of WEEE processes to the collection organisations. The “WEEE label of excellence" is therefore a unique opportunity to harmonise this very important task at European level.

Stakeholders were formally invited to express an interest in becoming a permanent member of the WEEELABEX Stakeholders Group (WSG), an advisory body. Today, the following organisations constitute the WSG: CECED, DigitalEurope, TechAmerica Europe, ELC, European Recycling Platform (ERP), European Electronics Recyclers Association (EERA), United Nations University, ACR+, European Environmental Bureau (EEB) and the WEEE Forum. Stakeholders are also invited to delegate experts to the WEEELABEX working groups.

The project will produce:

• Certification management procedures, such as formal requirements, the monitoring and auditing concept, and the sanction and cancellation procedure.
• Uniform rules of certification.
• Standards including technical requirements, documentation and reporting obligations, and managerial requirements with respect to WEEE management.
• The “auditor’s toolbox”, i.e. manuals, check lists, audit forms and so forth.
• A pool of auditors, familiar with WEEE processing technologies, trained to audit with respect to the standard.

Standards with respect to collection, de-pollution, recovery and recycling, and in particular observance of those standards, will result in better overall protection of the environment (and workers’ health and safety).

WEEELABEX envisages both management standards and technical standards. The scope of the management standards encompasses, amongst other things, reporting – the application of the WF_RepTool [click here for a demo version] – and documentation, batches and sampling, material flow management, and training. WEEELABEX envisages both management standards and technical standards. The scope of the management standards encompasses, amongst other things, reporting – the application of the WF_RepTool [click here for a demo version] – and documentation, batches and sampling, material flow management, and training.

The package of technical standards encompasses both product-specific standards and horizontal standards. Management of lead-containing cathode-ray tubes (CRT) television sets, mercury-containing liquid crystal displays (LCD) and mercury-containing gas-discharge lamps provide examples of vertical, product-specific standardisation. Examples of horizontal, cross-cutting standards: general requirements for collection, storage and transport of all types of equipment, general treatment requirements, specifications on de-pollution and pollutant retention, specification on recovery of secondary raw materials, and collection methods. Beside these WEEE specific requirements, general legal compliance with respect to environment and occupational health and safety (EHS) is required.

Early in the project, the key focus was on the development of a set of specifications related to WEEE collection, logistics, treatment and processing of all types of equipment (rather on the other Actions, such as certification, training of auditors, or pilot certification programmes). If the WEEE Forum organisations, in liaison with the stakeholders, deem the specifications sufficiently advanced in terms of overall support, they will be lodged with CENELEC, the EU electrotechnical standards body, to be accepted as EN standards. In the 4th quarter of 2009 and early 2010, additional sets of sub-standards will be developed related to management of particular types of equipment, such as monitors and displays, and lamps. CENELEC standardisation will bring the specifications developed under the project’s auspices into the public domain.

The standards will be based on a number of principles.

• The scope of the set of standards is given by the Directive and national legislation (and subsequent updates) concerning environmental protection and occupational health and safety requirements.
• The ultimate objective and criteria of setting up standards is the environmental performance with respect to feasibility, proportionality and the precautionary principle.
• The standards should be goal oriented, i.e. means, methods, tools, technologies or other technical equipment should not be set up as standards if not absolutely necessary.
• Rules and requirements impossible or impractical to verify should not be set up.
• Needless to say, the standards should be as concise as possible, clearly structured and easy to be understood by those who have to implement them. They will need to be reviewed periodically to update the specifications with respect to the experience of implementation.

In principle and as a rule, standards are not tailor-made to the specificities of a market. However, participants in the project will also discuss methodologies and eligibility criteria for operators that seek to be certified and labelled WEEELABEX but may take a longer time period to meet the all the requirements of the standard.

Once the standards are turned into CENELEC EN standards, they will by definition substitute for existing standards at national or sub-national level.

During the project period we intend to certify approximately:

• 15 cooling appliances treatment plants
• 25 regular WEEE treatment plants
• 8 lamp treatment plants

A “WEEELABEX Office” will be set up during the project. The main tasks of the WEEELABEX Office are related to:

• Implementation of the certification procedure, such as applicable formal requirements, the monitoring and auditing concept, and the sanction and cancellation procedure.
• Adherence to uniform rules of certification.
• Consultation of systems, certified or interested companies and authorities
• Coordination and supervision of the monitoring and auditing process
• Internal/external communication and awareness raising of the “WEEE Label of Excellence”

The WEEELABEX Office will be able to initiate and manage the whole certification process. It will provide advice to WEEE processors and collection and recovery organisations regarding certification, supervise the standards and the use of the label by the certified companies. It will mandate auditors to certify companies and supervise the whole certification process.

In time, existing certification companies will be mandated to administer the “WEEE Label of Excellence” and the issuance of certificates for WEEE management operators.

n 2009, the first year of the four year project – the project runs until end 2012 – the key focus of the project has been the development of a set of specifications related to WEEE collection, logistics, treatment and processing of all types of equipment. If the WEEE Forum organisations and the stakeholders deem the specifications sufficiently advanced in terms of overall support, they will be lodged with CENELEC, the electrotechnical EU standards body, to be accepted as EN standards. In the coming weeks, additional sets of daughter standards will be developed related to management of particular types of equipment, such as monitors and displays, and lamps. CENELEC standardisation will bring the specifications developed under the project’s auspices into the public domain.

In 2010, the WEEE Forum will start constructing a suitable (voluntary) certification architecture that is best adapted to the world of WEEE management. It is envisioned that instead of subjecting WEEE processors to similar audits for different clients, as was recently the case in Germany with respect to treatment of waste cooling equipment, we will establish one set of certification guidelines that auditors will apply uniformly.

Yes. The project aspires to lay down a set of requirements, based on legal requirements. In that sense, the standards will not be substantially more ambitious in terms of requirements than legislation. However, the methodical and consistent requirement for documentation clearly goes beyond anything that legislation requires.