[GRRN] Urgent help needed to defend EU takeback initiative

Okuzumi, Margaret (okuzumi@cepheid.com)
Mon, 5 Apr 1999 15:03:17 -0700

The Silicon Valley Toxics Coalition has launched a campaign
to counter U.S. electronics industry lobbyists who are trying to
persuade the European Union not to adopt new standards that call for
EPR. Please visit the SVTC website at
http://www.svtc.org/cleancc/weeeletr.htm and lend your group's
support to the campaign. Please also pass the word on to other
that are concerned about recycling and waste. Thanks very much for your

Greetings-We need your immediate assistance to help defend an important
new initiative that will help clean up the life cycle of computer
manufacturing and 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 is in danger of being significantly
weakened before it can even be implemented.

The "take back" initiative 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 Parliament.

We need you to send a letter right now, however, since there is a very
strong lobbying effort by industry to stop this landmark initiative. 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, etc.)

For additional background on this issue, you can find a copy of the
draft directive on our website. You can also view the position of our
allies the European Environmental Bureau (EEB) on their web page.

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: +32 2 296 0746

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

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

Dear Ms Bjerregaard, Mr. Currie, and Mr. Bangemann:

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

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

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 incineration.

Yours sincerely