[GRRN] Support Letters Needed: European Producer Responsibility

Bill Sheehan (zerowaste@grrn.org)
Sun, 21 Feb 1999 20:42:32 -0500

[Forwarded from the Silicon Valley Toxics
Coalition tsmith@igc.apc.org]


We need your immediate assistance to help
defend an important new initiative that will
help to phase out persistent, bio-
accumulative toxics and clean up the life
cycle of computer manufacturing. It will
also help solve the growing crisis of
excessive electronic junk. This new
directive from the European Union on Waste
from Electrical and Electronic Equipment
(WEEE) is under attack from U.S. based
electronics firms and the U.S. government
and is in danger of being significantly
weakened before it can even be implemented.

The "take back" initiative of the EU.
establishes Extended Producer Responsibility
(EPR) which places legal and financial
responsibility on the producers of
electronic and electrical goods throughout
the life cycle of their products - from
design through the end-of-life. This
initiative will not only encourage recycling
but also push for CLEAN PRODUCT DESIGN. Some
large manufacturers are lobbying to avoid
the life cycle responsibilities and are
trying to externalize the costs of recycling
to consumers and municipalities. We have
been asked by our allies in Europe to help
protect the directive. The European
directive, if implemented, will set the
global standard for Extended Producer
Responsibility, since all producers would
have to design new products to meet the
standard if they want to do business in
Europe. It will be voted on this Spring by
the Commission and then it will move to

Please send a letter right now, since there
is a growing lobbying effort by industry to
stop this landmark initiative, and the
commissioners need to know that many of us
in the U.S. are supporting their efforts. We
have heard reports that most of the industry
lobbyists are fighting against two important
components of the initiative-the section
that makes the producer financially
responsible for the take back, and the
phase-out of toxic materials (like PCBs,
specific endocrine disrupting chemicals,

For additional background on this issue, you
can find a copy of the draft directive on
our website at
www.svtc.org/cleancomputer/eudir.htm. You
can also view the position of our allies the
European Environmental Bureau (EEB) on their
web page at www.eeb.org.

Please take a few minutes to fax or send
letters on your own letterhead to the 3
commissioners listed below. Use the enclosed
text as a model. Please also send (or e-
mail) us a copy and we will add your name to
our website showing the international
support for this initiative. Thanks very
much for your support.


Ms Ritt Bjerregaard
Commissioner for the Environment
European Commission
Rue de la Loi 200
Brussels B-1049 Belgium
Fax: 011+32 2 296 0746

Mr. J. Currie
Director General DG XI
European Commission
Rue de la Loi 200
Brussels B-1049 Belgium
Fax: 011+32 2 299 0310

Mr. Martin Bangemann
EU Commissioner for Industrial Affairs
Rue de la Loi 200
Brussels B-1049 Belgium
Fax: 011+32-2-295-5637

Dear Ms Bjerregaard, Mr. Currie, and Mr.

We, of _____ support the European Union (EU)
initiatives on Producer Responsibility,
particularly the current proposed draft
Directive on Waste from Electrical and
Electronic Equipment. A good final directive
will have international benefits since it
will encourage similar Clean Production
initiatives outside Europe, particularly
within the United States.

We understand the EU is finalizing the draft
text this Spring and we want to particularly
emphasize the need to uphold the following
three main points:

First, we are in complete agreement with you
that the producer or distributor of all
electronic products and electrical equipment
must be financially responsible for managing
the product at the end of its life. This is
because only the producer has control over
the design of a product. We do not believe
local authorities or the public at large
should have to pay for waste management
costs of electrical and electronic equipment
because we as consumers have no
participation in the decision making process
at the product design stage.

Proposals that
place the costs of waste management on local
authorities require that local taxpayers
have to pay not only for the product but
also for the costs of managing the hazardous
materials that producers choose to use
within their products such as PVC plastics,
flame retardants, lead, and other hazardous
materials. We believe that placing the
financial responsibility for take-back on
the producer will encourage better product
design such as durability, repairability and
cleaner material use.

Second, we strongly support the current
requirement of the European Commission to
ensure, as a minimum, the phase out of
brominated flame retardants, cadmium, lead,
mercury and hexavalent chromium within
electronic products. These chemicals are
highly hazardous and persistent in the
environment, are a known health danger and
some are even acknowledged hormone
disrupting chemicals. The use of these
chemicals in domestic products must be
phased out as a priority. Only this will
help to clean up the entire product chain
and help to alleviate worker health problems
within the electronic industry as well as to
reduce these hazardous emissions to the
environment upon disposal. However this is
only a beginning and we ask that the
Commission include PVC plastic and all
halogenated materials for phase out as well.
The goal of this directive should be the
elimination of all carcinogenic, toxic and
endocrine disrupting chemicals in electronic
and electrical equipment.

Third, we agree with the draft text that
incineration or energy recovery from
incineration is not considered reuse or
recycling. We oppose the use of incineration
as a possible disposal route for end of life
electrical and electronic waste. We believe
that producers should first design products
for durability and upgradability, thus
reducing the flow of materials from resource
use to final end of life. Recycling of
materials at the end of a product's life
must eventually cause no harm to worker
health or the environment, hence the need
for toxic-free materials within the product.
We note that the first draft directive had
no inclusion of incineration as a possible
disposal route but now this has been
reinstated as a possibility for 10 to 30
percent of electronic scrap for some
products. We urge the Commission to re-
instate the previous exclusion of all

Yours sincerely

(add your name here)

Ted Smith
Silicon Valley Toxics Coalition
760 N. First Street
San Jose, CA 95112

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