Electrical and Electronic Waste

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Electrical and Electronic Waste

On 27 January 2003, two Directives entered into force within the EU. The first (RoHS) concerns constructional materials used for electrical and electronic equipment and does not concern us here, except to mention that it will cause far more environmental harm than it will ever prevent. The second is Directive 2002/96/EC on "waste electrical and electronic equipment (WEEE)"[Download]. Both directives are vaguely worded and are quite open to interpretation and may be expected to be the subject of considerable debate.

The general purpose behind WEEE is to reduce the risk of pollution caused by electrical equipment being disposed of by being deposited within a landfill or by other means. As such, this is laudable. Instead, it should be recycled to a maximum. This maximum, to be attained by 31 December 2006, varies, by weight, from 70% (for small household equipment and similar) to 80% (for large household appliances and dispensers). Components removed from the equipment benefit from reduced percentages; for example, a PC should be recycled to 75% but a graphics card taken from it should be recycled to 65%. The fact that the latter is impossible to achieve does not appear to have fazed the rulemakers!

One of the main points of this Directive is contained within Article 5. Briefly summarised, this states inter alia:

	Member States (i.e., including Cyprus) must implement measures to achieve a high level of separate collection of WEEE
	By 13 August 2005, systems are set up to ensure free-of-charge collection of WEEE from private households
	Distributors (i.e., retail shops) are obliged to take back on a one-to-one basis old appliances when a customer purchases a new one of equivalent type
	Producers may set up their own take-back systems from private households
	Collected WEEE should average at least 4 kg per inhabitant per year from private households by 31 December 2006
	Member States are obliged to transpose the Directives into national law by 13 August 2005.

I find that one of the controversial points is the 4 kg/inhabitant/year rule. Cyprus is a country with large families, often with minimal incomes. It is one thing for a professional childless couple always buying the latest gadgets and changing them regularly to produce 8 kg of waste electrics per year, but it is grossly unfair to expect families with 4 children with only a small fridge and a TV set to produce 24 kg/year, every year.

So, has Cyprus transposed the Directives? This is what I found:

CYPRUS
TRANSPOSITION OF THE WEEE AND RoHS DIRECTIVES: CURRENT STATUS
Regulation 68-204 transposing the RoHS and WEEE Directives was approved by Parliament on 30 July 2004
Financing of WEEE from households:
Producers, not local authorities, are required to finance collection and sorting as well as transportation and treatment of WEEE from households.
Local authorities are not obliged to collect WEEE.
National Register:
Producers must register with the Environment Service of the Ministry of Agriculture, Natural Resources and Environment.
System requirements:
A joint system is to be approved by the Environment Committee, which consists of representatives of several Ministries.
RECOVERY ORGANISATIONS (COMPLIANCE SYSTEMS)
No meetings have as yet been scheduled to prepare for implementation of the new Regulation.
There are no producers of electronic equipment in Cyprus.

Let's look at the last sentence first. There are no producers of electronic equipment in Cyprus. Even this is not strictly accurate, there are possibly a few tens of companies producing electronic equipment on the island, albeit in small quantities. However, it's clear we have no Siemens, Sony or Dell factories on the island. These companies, that do not apparently exist, still have to register with the MANRE, as well as finance the collection and sorting of the WEEE. However, life is not quite that simple; the Directive defines a "producer" as "any person who, irrespective of the selling technique used, including by means of distance communication ...:
(i) manufactures and sells electrical and electronic equipment under his own brand,
(ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the 'producer' if the brand of the producer appears on the equipment, as provided for in subpoint (i), or
(iii) imports or exports electrical and electronic equipment on a professional basis into a Member State."

So, by this definition, there are many "producers" in Cyprus and the Government simply has got it wrong. Quite apart from the fact that any astute lawyer could drive a horse and cart through this definition (and many other points in the Directive), my first reaction on reading the Transposition document is that the Government is paying lip service to the Directives but are weaseling out of seriously implementing them. No meetings have as yet been scheduled to prepare for implementation of the new Regulation. Yet the system must be in place by 13 August 2005. How can this be?

There is another point that needs examination. Some WEEE will contain metals and other substances that must be considered as very toxic. These will have no market value on the island, nor are there any means of safely disposing of them. Whether the waste is recycled on the island or not, these toxic materials must be disposed of safely but they will be classed as hazardous waste. This implies they will have to be exported. This will imply that they come under the aegis of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal [Download]. The cost of complying with this will not be insignificant. To give you an idea of the size of this problem, virtually all electronic and some electrical equipment contains lead and lead compounds (some contain even more toxic metals, such as arsenic and cadmium) and will automatically be considered as hazardous waste when taken out of service. Even if the lead were separated out, it will be impure and will still be hazardous waste when sent elsewhere for re-use.

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