EucoLight represents producer responsibility organisations (PROs) that collect and recycle
WEEE lamps and lighting products on behalf of their participating producers, working to make
circular economy a reality for lighting products. We support the extensive work undertaken by
the European Commission to improve the Directive 2012/19/EU on WEEE in the context of the
future Circular Economy Act. EucoLight has actively participated in the various consultations
and stakeholder meetings relating to the functioning and improvements of the WEEE Directive
and elements for the upcoming Circular Economy Act impact assessment. This position paper
will focus on the main priorities for EucoLight members.
Our recommendations in brief:
- Transform the WEEE Directive into a single Regulation focused on Waste.
- Keep all lamps, including LEDs, in the same EEE category to preserve the sustainability
of the sound waste management of all lamps. - Review the collection target calculation methodology to reflect the long lifetime of
lighting products. - Adapt recycling targets of lamps to product technology.
- Ensure all collection flows (PROs, distributors, municipalities, waste operators) count
toward national targets. - Strengthen extended producer responsibility (EPR) with clear obligations for all actors
across the waste chain. - Apply strict safeguards to individual EPR systems, limiting them to B2B and ensuring
traceability. - Reject State‑run PROs to preserve independence, producer expertise and system
performance. - Harmonise the definition of “placing on the market” and align POM rules across the EU.
- Tackle online free‑riding through platform verification duties and stronger authorised
representative requirements. - Create interconnected national registers and move toward an EU‑wide digital one‑stop
shop linked with customs. - Strengthen enforcement powers for Member States to inspect waste flows and verify
data reliability.
