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Legislation, REACH, WEEE and RoHS News
News Release from: RAL: Quality Assurance Association
Edited by the Processingtalk Editorial
Team on 10 April 2006
Implementation of the WEEE directive in
Germany
RAL is demanding more stringent control mechanisms for the German market to guarantee the transparency of the fridge recycling process and ensure full compliance with minimum environmental standards
The practical implementation of the European WEEE directive in Germany has been ongoing since 24 March In addition to the issues of registration and financing, much of the current discussion is focused on the logistical aspects of implementation
This article was originally published on Processingtalk on 28 Dec 2005 at 8.00am (UK)
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In the opinion of the RAL Quality Assurance Association, however, the main purpose of the WEEE and the German Electrical and Electronic Equipment Act (ElektroG) - both primarily pieces of environmental legislation - has been pushed firmly into the background, raising once again the question of how best to realize quality assured, transparent demanufacturing of WEEE.
No other development in the last twenty years has caused such radical changes to the German waste management sector as the implementation of the WEEE directive.
From one day to the next, the obligation to ensure the proper treatment of waste electrical and electronic equipment was transferred from the approximately 450 German local authorities and public bodies to producers or producer consortia.
Further reading
Efficient fridge recycling is essential
This year's extreme summer weather has brought back into focus an environmental problem that is still seriously underestimated by the public in general: the effects of fridge recycling
Residual CFCs still a major cause for concern
For Europe, the number of refrigerator or freezer appliances containing CFCs still in use is estimated to be around 200 million - equivalent to about 100,000 tonnes of CFCs
Climate: A serious issue for fridge recycling
The World Climate Conference in Nairobi spawned alarming news on the state of global climate protection: It is essential that fridge recycling activities are subjected to rigorous critical appraisal
That there would be teething problems due to the complete reorganization of the transport logistics was clear to many experts beforehand, though some of the obstacles that have arisen were not predicted.
Nevertheless, the RAL Quality Assurance Association is confident that these logistics problems will be resolved relatively swiftly.
Of more importance but forced into the background due to current developments is the question of the quality of the treatment of end-of-life electrical equipment, particularly the fate of waste fridge and freezer appliances.
The RAL Quality Assurance Association believes that there are three elements of key importance to both the producers and the monitoring authorities.
* Transparency of fridge treatment procedures.
* Recovery of minimum quantities of CFCs based on the internationally recognized RAL standard.
* Material flow monitoring.
If waste removal logistics remain organized as at present, the fate of waste refrigeration equipment will continue to be highly opaque to outside observers.
It seems questionable whether it is really possible to monitor compliance in order to verify that waste appliances are actually being treated in the recycling plants specified in the original tender.
There is a very real risk that without fully transparent monitoring processes, customers will pay for high-quality recycling at plant A, even though the waste appliances are actually subjected to lower quality treatment at plant B for the simple reason that it is cheaper to transport the waste to the latter plant.
Similarly, the illegal export of waste appliances to non-European countries, where quality levels may be poor, will also go undetected unless transparent and continuous processing procedures and control mechanisms are systematically introduced in the near future.
The Federal Republic of Germany has generally accepted principles that are laid out in the LAGA1 guidelines on electrical and electronic waste and that represent the accepted state-of-the-art in fridge recycling.
As important sections of the RAL GZ-728 quality assurance scheme for fridge recycling were incorporated into the LAGA guidelines, the process benchmarks determined by RAL can be regarded as accepted minimum quality requirements in this environmentally sensitive area.
However, according to the RAL Quality Assurance Association, these targets have still to be achieved in practice.
The association fears that given the current status of WEEE implementation in Germany, the quality standards set out in the LAGA guidelines and the RAL GZ-728 specifications will be subjected to little or no testing or verification.
What is needed is a regulatory body that undertakes regular checks of recycling channels and that tests the efficiency of the recycling technology used to ensure compliance with the requirement to use the best available technology.
This criticism has led to producers and producer groups in a number of European countries reconsidering their approach to fridge recycling.
In Germany, however, the question of whether quality requirements are being met in practice is still based on trust alone.
The RAL Quality Assurance Association is aware that the local authorities, which were previously responsible for the disposal and recycling of electrical waste, have been receiving increasing numbers of enquiries from consumers regarding the quality of the treatment to which electrical scrap is subjected.
According to reports, many local authorities are unable to provide the information that they are obliged to supply to consumers simply because process transparency is lost as soon as the waste refrigeration equipment has been collected for treatment.
In view of this situation, the RAL Quality Assurance Association is demanding more stringent control mechanisms for the German market that will guarantee the transparency of the fridge recycling process and ensure full compliance with the minimum environmental standards demanded by environmental regulations and legislation.
Tighter quality controls would also mean that consumers, who contribute financially to recycling costs when they purchase a fridge or freezer appliance, would be assured that end-of-life appliances are being recycled in an environmentally benign and transparent way.
The RAL Quality Assurance Association has been actively promoting quality-assured fridge recycling across Europe for more than eight years and is prepared to share its extensive expertise and support the establishment of a quality monitoring unit for the German fridge recycling sector.
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