Mittlerweile ist Grossbritannien dabei seine nationale Umsetzung der WEEE vorzubereiten. Nach den offiziellen Verlautbarungen herrscht auch dort eine völlig Wahrnehmungsverzerrung was den Markt betrifft. Aber es gibt die Möglichkeit Kommentare abzugeben:
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UK setzt WEEE um
Moderator: Guido Körber
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Guido Körber
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Guido Körber
- Site Admin
- Posts: 2856
- Joined: Tue Nov 25, 2003 10:25 pm
- Location: Germany/Berlin
- Contact:
Mein Kommentar an die britische Kommission:
Dear Sir or Madam,
since you are in the process of converting the WEEE directive into national law we would like to provide some input from the perspective of small and medium business.
Most national WEEE legislation has created a big mess that is going to kill a large number of smaller companies and going to cost many jobs. Also most national implementations of WEEE are in conflict with european law, especially the common market rules.
The national WEEE laws require a manufacturer to be registered nationally to sell products into the national market. But most of the national laws allow registration only if the registering company has at least a branch office in that country. This is a definite violation of the common market rules. Please make sure that your national implementation will provide a reasonable way for companies from other EU states to register and sell in the UK market.
Germany has created a genuine mess with the WEEE implementation. It basically makes it impossible for anything less than a multinational concern to stay within the law. Several definitions in the German law are extremely fuzzy, including a contradiction in the B2B and B2C definition which is different for putting a product into the market and for returning/recycling it.
The returning/recycling mechanisms are specifically designed for the needs of large corporation. I can understand their interest in having a system that allows them to optimize the costs of recycling large quantities of electronic waste. But the smaller companies can simply not live with a system that assigns a full container of waste by means of a lottery. In addition to the large scale recycling with all the mechanisms for returning and financing it is absolutely necessary to implement a second option. The companies should have the option to either use the large scale system or to pay a flat fee per unit that covers all the returning and recycling, the Swiss have such a system and it works.
A small company producing maybe a couple 100kg of electronic devices per year will have no problem if they have to pay several times the price for recycling per tonne compared to a large company with thousands of tonnes per year. But a small company has a big problem with a cost structure like in Germany where you pay orders of magnitude more in fees than for the actual recycling (i.e. about 800-1000€ fees compared to 20€ actual recycling cost for 100kg, or obligations to put 1€ into a bankruptcy safe deposit).
When making the final law please keep in mind that this whole law makes no sense if it kills thousands of small companies. The German law alone has the potential of costing thousands of highly qualified jobs until the end of this year. We even have examples where companies that make measurement devices for environmental protection will have to give up because of the WEEE.
Best regards
Guido Körber
Dear Sir or Madam,
since you are in the process of converting the WEEE directive into national law we would like to provide some input from the perspective of small and medium business.
Most national WEEE legislation has created a big mess that is going to kill a large number of smaller companies and going to cost many jobs. Also most national implementations of WEEE are in conflict with european law, especially the common market rules.
The national WEEE laws require a manufacturer to be registered nationally to sell products into the national market. But most of the national laws allow registration only if the registering company has at least a branch office in that country. This is a definite violation of the common market rules. Please make sure that your national implementation will provide a reasonable way for companies from other EU states to register and sell in the UK market.
Germany has created a genuine mess with the WEEE implementation. It basically makes it impossible for anything less than a multinational concern to stay within the law. Several definitions in the German law are extremely fuzzy, including a contradiction in the B2B and B2C definition which is different for putting a product into the market and for returning/recycling it.
The returning/recycling mechanisms are specifically designed for the needs of large corporation. I can understand their interest in having a system that allows them to optimize the costs of recycling large quantities of electronic waste. But the smaller companies can simply not live with a system that assigns a full container of waste by means of a lottery. In addition to the large scale recycling with all the mechanisms for returning and financing it is absolutely necessary to implement a second option. The companies should have the option to either use the large scale system or to pay a flat fee per unit that covers all the returning and recycling, the Swiss have such a system and it works.
A small company producing maybe a couple 100kg of electronic devices per year will have no problem if they have to pay several times the price for recycling per tonne compared to a large company with thousands of tonnes per year. But a small company has a big problem with a cost structure like in Germany where you pay orders of magnitude more in fees than for the actual recycling (i.e. about 800-1000€ fees compared to 20€ actual recycling cost for 100kg, or obligations to put 1€ into a bankruptcy safe deposit).
When making the final law please keep in mind that this whole law makes no sense if it kills thousands of small companies. The German law alone has the potential of costing thousands of highly qualified jobs until the end of this year. We even have examples where companies that make measurement devices for environmental protection will have to give up because of the WEEE.
Best regards
Guido Körber
Hallo Herr Körber,
haben Sie den Kommentar schon platziert? Ansonsten hätte ich noch einen kleinen Verbesserungsvorschlag: Die Schweizer Rücknahmesysteme SWICO und SENS sind in UK nicht sehr beliebt weil sehr teuer, es wäre vielleicht taktisch geschickter das schwedische El-Kretsen System als Positivbeispiel anzuführen, dann ist man eher auf einer Linie mit britischen Herstellern.
haben Sie den Kommentar schon platziert? Ansonsten hätte ich noch einen kleinen Verbesserungsvorschlag: Die Schweizer Rücknahmesysteme SWICO und SENS sind in UK nicht sehr beliebt weil sehr teuer, es wäre vielleicht taktisch geschickter das schwedische El-Kretsen System als Positivbeispiel anzuführen, dann ist man eher auf einer Linie mit britischen Herstellern.