The digital industry’s views on Extended Producer Responsibility under Article 8a

INTRODUCTION

The digital industry is very positive about the circular economy and strongly supports moves to implement circular economy practices and thinking.

This paper provides a response to the proposals for new requirements for Extended Producer Responsibility (EPR) within the proposed new Article 8a of the Waste Framework Directive. We set out some general observations to the draft Article 8a and beneath these we examine in more detail the legal text that has been proposed, our analysis of its interpretation and implications, and propose, where appropriate, alternative wording.

This submission reflects the views of manufacturers of electronic and electrical products in the B2B, consumer electronics and telecommunication markets, who have responsibilities under three producer responsibility regimes: waste electrical and electronic products, batteries and packaging.