RoRec in the group of “first movers” for the implementation of the WEEELABEX standards for WEEE* management

At its meeting in Amsterdam on 1 April 2011, the General Assembly of the WEEE Forum approved the standards (consolidated into version 9) and decided that they will not be subject of modifications for a period of 18 months (until 1 October 2012)

November 2011 - From the Print Edition

In those 18 months, a number of producer responsibility organisations (PRO) of the WEEE Forum will ‘test’ the standards, they will gather experience on their implementation on the ground by the operators. The Romanian Association for Recycling – RoRec is part of the vanguard of ‘early birds’ that will implement the standards in 2011 and 2012 together with organizations from: Belgium, France, Germany, Italy, Switzerland and The Netherlands.

WEEELABEX is the acronym (‘WEEE LABel of EXcellence’) of a project, run by the WEEE Forum in co-operation with stakeholders from the producers’ community and processing industry.
Producers and recyclers associations are represented in both working groups and the project’s steering group (CECED, ELC and DIGITALEUROPE, and EERA). The project (2009-2012) is co-financed by the European Community under the LIFE program (LIFE07 ENV/B/000041). It aims to design, on the one hand, a set of European standards with respect to the collection, sorting, storage, transportation, preparation for re-use, treatment, processing and disposal of all kinds of WEEE, and, on the other hand, a harmonized set of rules and procedures that will provide for conformity verification.

More particularly, the project is resulting, across Europe, in:
- Less pollution.
- More sustainable activities, in particular higher levels of recovery of secondary raw materials (resource efficiency).
- Better occupational conditions for workers.
- Assurance of a more transparent material flow management and adequate de-pollution processes through proper documentation and reporting.
- Reduced scope for illegal shipments of WEEE.
- European standards and guidance documents that will more flexibly address new (technological) developments.

It will create incentives for operators to meet a set of uniform standards, and disincentives for dishonest companies to dodge ‘the system’, and hence, a level the playing field for WEEE management companies.
The WEEELABEX project was born against a specific legal, environmental and commercial background.
Some collection, logistics and recycling sites fail to properly store or handle WEEE, resulting in uncontrolled emissions. Today, in Europe, a patchwork of both legal and contractual requirements, of different ambition and enforced with different levels of determination, hinders processing companies’ economies of scale and creates an uneven playing field.
In some parts of Europe, WEEE treatment technologies are cutting-edge and workers’ safety is properly ensured, while in others de-pollution and mechanical treatment is performed in workshops with inadequate safety measures or inappropriate shredder technologies.
New types of electrical and electronic equipment are marketed that require specific de-pollution techniques or practices. In some parts of Europe, downstream operations are carefully monitored and documented, while in others consumers and electronics producers paying for the management of WEEE have no such assurance.
The project aspires to design, on the one hand, a set of European standards (or ‘normative requirements’) with respect to the collection, sorting, storage, transportation, preparation for re-use, treatment, processing and disposal of all kinds of WEEE, and, on the other hand, a harmonised set of rules and procedures that will provide for conformity verification.
Operators that fall within the scope of the project are: collection sites, logistics sites, transporters, and facilities involved in dismantling, de-pollution, preparation for re-use, disposal and recycling.
The standards concern all steps in the chain, from collection to disposal. Operators involved in WEEE operations will be audited by WEEELABEX auditors, trained in accordance with the standards. Facilities and sites that meet the requirements will be identifiable. No label or visual identifier will be awarded to companies or legal entities as such.
Operators will have to be in a position to assess conformity of their activities with the standards and to demonstrate that they have contracted with WEEELABEX (or WEEELABEX-equivalent) partners. The project can be considered of an open nature in the sense that any organization that accepts the obligations of WEEELABEX can join the scheme.
Both the WEEELABEX standards and the WEEELABEX project as a whole are original and innovative for a number of reasons.
For the first time ever, a harmonized, continental set of (technical) normative requirements (standards) and guidance documents affecting all parties involved in WEEE operations, from collection to disposal, and covering all 10 WEEE categories is laid down, respecting legislative requirements of Directive 2002/96/EC on WEEE and its transposing national laws and decrees.
The WEEE systems of the WEEE Forum, representing approximately two thirds of officially reported WEEE collection in Europe, will contractually require the collection sites, logistics facilities and recycling plants to implement the standards. In other words, WEEELABEX will have an immediate and grand-scale impact on the entire WEEE chain, from collection to disposal.
The set of standards is not only likely to be acknowledged by authorities as a new ‘benchmark’ but will probably resonate globally as well. Operators in other parts of the world will likely wish to adhere to an equivalent level of principles.
The project starts off to produce requirements to be integrated into contracts of WEEE systems with operators. Yet (part of) those requirements will likely end up becoming formal EN standards, affecting all operators on the market, not just those with whom the PROs of the WEEE Forum have entered contractual terms. But even in the short term, the WEEELABEX standards are likely to be adopted by parties with whom producers recycling organizations of the WEEE Forum have no contracts.
At the time of writing, Directive 2002/96/EC is being recast. The future recast Directive might specify that operators meeting the provisions of a standard, the development of which by European standardization organizations is mandated by the European Commission, will be presumed to comply with the Directive. Those so-called ‘harmonized standards’ are expected to arise from the WEEELABEX set of standards.
The novelty and ambition concerns the fact that WEEELABEX expects parties to be in a position to monitor downstream operations; it lays down uniform, specific, verifiable and comprehensive reporting and documentation obligations, most of which are not, as such, legally required. The reporting will follow the principles and reporting format provided by WF_RepTool, the WEEE Forum’s web-based tool that allows operators to communicate recycling and recovery quotas to WEEE systems on the basis of a harmonized reporting classification (WF_RepLists).
Also for the first time ever, a European scheme is being constructed that harmonizes the rules for the verification of conformity with the normative requirements. The scheme is of a private and “sui generis” nature – it will affect the WEEE Forum and other contracting parties – yet is expected to demonstrate how European rules can be enforced in a harmonized manner.
Monitoring of conformity with the standards will refer to specific concentration and target limits, not to a generic, unspecified ambition of ‘continuous systemic improvement’.
In August 2009, the WEEE Forum signed a contract of co-operation with CENELEC, one of the three official EU standards bodies. In time, (some of) the requirements of the WEEELABEX normative documents will likely be translated into formal CENELEC EN standards.

The standards aim to:
- Achieve adequate de-pollution, treatment and disposal of all types of WEEE in order to prevent pollution and minimize emissions.
- Promote high quality recovery of secondary raw materials.
- Protect human health and safety.
- Prevent illegal (cross boundary) shipments of WEEE and fractions thereof.
- Level the playing field for all actors in the WEEE chain.

The standards are based on the precautionary principle and on the principles that preventive action should be taken, environmental damage should as a priority be rectified at source and the polluter should pay. The requirements are also based on the presumption that operators adhere to the principle of due diligence with all activities. Due diligence includes understanding of all obligations to which the company is subject and transparency with business partners.
The WEEELABEX standards package structurally consists of three documents, one aimed at operators performing collection of WEEE, one aimed at logistics operators and one aimed at treatment operators.