Margot Wallström's department has yet to officially respond to the EEE proposal, which came without any formal consultation. A source told ENDS Daily it would certainly be rejected even though it conflicts with almost none of the specific proposals in the WEEE directive, adding that it was being seen as an incursion into what the environment directorate sees as its sovereign territory.
The overall aim of Mr Liikanen's plan is to "ensure that the overall impact of the equipment during their life-cycle is minimised." Under the proposals, manufacturers of electrogoods would have to perform a "conformity assessment" on their products. Only those with a positive assessment would have access to the EU market. In practice, this would mean that manufacturers could choose either to apply an "internal design control" to their manufacturing procedures or to follow an environment management system, both of which are defined in annexes to the directive.
Whichever route companies chose to take to compliance, they would have to use "environmental impact assessments" to make "specific design choices" leading to the development of products that do not have avoidable environmental impact[s] and are "efficient in their consumption of energy and natural resources."
This will entail them having to "avoid the undue use of devices, components, materials or substances presenting a threat to the environment at the end of their life-cycle...minimise or control pollution during the normal use of the equipment," and achieve a "reasonable balance" between product function and impact.
Companies would also have to use best available technology where "economically viable and cost effective," and "optimise [the] life-cycle duration of the equipment." Product designs would have to be reviewed whenever "adverse environmental impacts might be significantly reduced by the application of new knowledge...and developments in the state of the art in environmentally friendly design."
EU industry body Orgalime has welcomed the enterprise department's move, claiming in particular that it could herald a more flexible approach by the EU to the use of product-related directives to ban toxic substances. However, a spokesperson for the association told ENDS Daily that the document had been hastily drafted with little consultation, and that "a lots of points in it need to be revised."
European Commission, tel: +32 2 299 1111.
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