The European Waste Management Association (FEAD) and the European Electronics Recyclers Association (EERA) issue joint response to the possible integration into the Organisation for Economic Co-operation and Development (OECD) decision of recent amendments to the Basel Convention.
In the statement, the two organisations say they ardently believe that the harmonisation and improvement of regulations intended for the shipment of waste will bring about the prevention of the dumping of untreated e-wastes in those countries without the correct infrastructure and knowledge to ensure that harmful substances are eradicated.
Following the last Basel Convention e-waste amendments and the ongoing discussion about their integration into the OECD Decision, FEAD and EERA say they consider it crucial to bring the need for clear and efficient shipment rules to the negotiation table.
To enable the circular economy in a competitive and innovation-driven way, the two organisations say waste managers need an economy of scale in which end-of-life products can find their way to the most adequate and specialised facilities to be recycled into valuable secondary raw materials that will re-enter the product’s value chain.
Notification procedures are currently long and burdensome, which needs to change if we want to make the circular economy a reality.
Unnecessarily heavy, costly, and lengthy procedures are trade impediments to circular business models, the two organisations say, which should be based on open and safe markets. Following a survey among the Members of both Associations, the results show clear deficiencies and big disparities, for example, in the implementation of the Prior Informed Consent (PIC) procedure.
It is therefore critical to update and improve the procedure to make it simple, online and transparent, the two organisations say, strengthening the pre-consent status for facilities and revising the financial guarantees by including a risk-based approach.
FEAD and EERA strongly advocate for such improvements that will facilitate the trade of recyclables in an environmentally sound and economically efficient manner and hope that the practical examples provided will serve the legislator and competent authorities to address the issue and implement the needed reforms in the system.
Peter Kurth, FEAD President said: “Notification procedures are currently long and burdensome, which needs to change if we want to make the circular economy a reality. In this sense, the unification and harmonisation of administrative costs are also important.
“These are currently prohibitively high and not proportional to the risk, costs or work involved, and significantly increase the overall financial burden of legitimate global e-waste operators.
“What we are asking for is harmonised, transparent, risk-based requirements that result in reasonable and justifiable administration costs”.
