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ETIRA meets German regulator to discuss empties under WEEE directive

March 28, 2014

ETIRA representatives l. to r.: Andreas Schelle  (Interseroh),  Hans- Gerhard Hermans (Return Recycling), Florian Werthmann  (CR-Solutions), Marc  Berger ( Pelican Hardcopy), Vincent van Dijk (ETIRA)

ETIRA representatives l. to r.: Andreas Schelle (Interseroh), Hans-Gerhard Hermans (Return Recycling), Florian Werthmann (CR-Solutions), Marc Berger(Pelikan Hardcopy), Vincent van Dijk(ETIRA)

The association met with UBA to insist that empties should not be included as WEEE under the new WEEE directive.

The meeting between ETIRA representatives and German regulator UBA, which is responsible for the WEEE directive, took place in Dessau on 26 March as a follow-up to a letter sent to UBA by ETIRA in October 2013. In the letter, ETIRA protested UBA’s decision to include almost all empty cartridges under the new WEEE directive (WEEE-2), which will be implemented in Germany for a five-year review period.

ETIRA used the meeting in Dessau as an opportunity to argue that including cartridges in the scope of this law is a violation of EU law, as well as being bad for the environment; and that if all printer cartridges are classified as WEEE, current availability of empty cartridges on the open market could diminish. ETIRA noted that many local authorities across Germany have no capacity to collect all empty cartridges separately during the printer’s life cycle, and so many more empty cartridges would be sent directly to landfill and/or incineration after their first use rather than being reused.

As a result, ETIRA insisted that the status quo should be maintained for printer cartridges throughout the upcoming five-year WEEE review period until 2018 at least.

In response, while UBA made it clear that they think cartridges should be in scope of the WEEE directive, they also agreed that they support the remanufacturing of cartridges; and so both organisations jointly addressed the challenges that a reclassification may present. ETIRA suggested that it would be acceptable for cartridges to be included under the scope of WEEE only under the condition that sufficient tools are in place to allow a full availability if empties; and it was agreed that both UBA and ETIRA will explore the different ways to facilitate this.

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