Phil Agre on Mon, 1 Mar 1999 01:15:50 +0100 (CET)

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<nettime> [RRE]EU Directive on Waste from Electrical and Electronic Equipment

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Sent: Tuesday, February 16, 1999 1:28 PM
From: Ted Smith <>
Subject: clean computer campaign action alert

Greetings to our CINeter friends!

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 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 at
You can also view the position of our allies the European
Environmental Bureau (EEB) on their web page at

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 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 incineration.

Yours sincerely

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

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