In cooperation with its members, EucoLight publishes position papers, consultation papers and press releases. Thereby fostering a constructive dialogue between the European institutions and stakeholders and working to make the Circular Economy a reality for lighting products.
JOINT STATEMENT ON AMENDING THE ANNEXES OF REGULATION (EU) 2019/1021 ON PERSISTENT ORGANIC POLLUTANTS (POPs)
Issued February 2022
Adopted in June 2019, the recast Regulation on Persistent Organic Pollutants (POPs) set the contaminant limits that largely determine the treatment of the waste and, in particular for limits in Annex IV, define whether a waste containing specific POP substances should be disposed of in such a way that the POP content is destroyed or irreversibly transformed or whether it can be subjected to other recovery or disposal operations, including recycling.
The entry concerning PBDEs (including DecaBDE) in Annex IV contains a clause requiring the Commission to review the Low POP Concentration Limit (LPCL) for these substances by 16 July 2021. The limit value for the substances is currently set at 1,000 mg/kg. The Commission was asked to look at the feasibility of reducing the aforementioned value to 500 mg/kg as finally published on 28 October 2021.
The signatory organisations to this position paper acknowledge the challenge set out by the Commission and believe that the discussion and decision around any revision of the LPCL for PBDEs needs to be based on current scientific knowledge and the factual situation concerning the sound waste management and treatment of POP containing materials in the electrical, electronic and automotive sectors in the EU.
EUCOLIGHT FEEDBACK ON THE CALL FOR EVIDENCE: ENVIRONMENTAL IMPACT OF WASTE MANAGEMENT- REVISION OF EU WASTE FRAMEWORK
Issued February 2022
EucoLight responsed to the call for evidence for an impact assessment on revision of EU waste framework making a series of recommendations on:
Extended producer responsibility requirements that have not been adequately addressed in Article 8a of the 2018 Directive or for which the compliance should be improved;
Accuracy of EEE and WEEE data, and the need to avoid contamination of waste streams;
The collection of end of life products under EPR policies;
Improving enforcement of EPR requirements, in particular for products sold online to customers in the EU.
REPORT- TECHNICAL FEASABILITY ANALYSIS FOR THE IDENTIFICATION OF TYPES OF LAMPS IN RECYCLING STREAMS
A study performed by Fraunhofer IZM and mandated by EucoLight
Issued July 2021
This report presents a technical feasibility study on the technology assessment for the separation of collected End-of-Life (EoL) lamps, more specifically the technical possibilities for separating conventional gas discharge lamps (GDLs) from conventional light-emitting diode (LED) lamps.
The project consisted of first a theoretical phase in which technological possibilities for sorting methods were explored and described. Based on this potential analysis, followed the testing phase, concentrating on static and dynamic testing with three promising sorting technologies. Ultimately however, only two methods, the blue light and electromagnetic induction tests, were considered promising and carried out in detail.
Issued 09 December 2021
On the occasion of the vote on the Digital Services Act (DSA) in the IMCO committee, Eucolight has prepared a short statement whose purpose is to point out the essential elements that should be reflected in the final version of compromise amendments in order to stop the flow of non-compliant product into the Union.
EucoLight is of the opinion that the compromise amendments should include a specific liability regime for online platforms that allow consumers to conclude distance contract with traders, and should foresee strong due diligence obligations for online marketplaces.
JOINT CALL BY BUSINESS, CONSUMER AND CIVIL SOCIETY ORGANISATIONS ON THE DIGITAL SERVICES ACT (DSA): EFFECTIVE AND UNAMBIGUOUS RULES ARE NEEDED TO TACKLE ILLEGAL ACTIVITIES AND ROGUE TRADERS
Issued 11 October 2021
EucoLight joins forces with 29 other city society and industry groups to ask policymakers that the Digital Service Act holds accountable online platforms that facilitate the initiation of transactions between traders and end-users via a strong liability regime and firm obligations.
The Digital Service Act is the perfect opportunity to address the access of illegal products to the Internal Market via online platforms. In order to do so, in the joint statement it is proposed that they should not be exempt from liability when:
• They are aware of an illegal activity on their interfaces and do not take immediate action; or
• They exert a decisive influence on the trader or the transaction; or
• There is no party based in the EU that can be held liable for an illegal activity online on their platform; or
• They do not comply with their own DSA due diligence obligations, such as the know your-business customer obligation.
Issued 20 July 2021
Eco-modulation task force response to the 2018 Directive 2018/851/EU on Waste, the WEEE Compliance Promotion Exercise and the 2019 Commission’s draft Guidelines on general minimum requirements.
Objective of the task force is to proactively set the framework, principles and mechanisms for a harmonised eco-modulated fee scheme in Europe which is compatible with both:
existing EPR implementation
and the producer community’s current calls for system change as outlined in “An enhanced definition of EPR and the role of all actors”.
The task force set out to explore:
which criteria and products can be selected for eco-modulation,
how to develop a simplified fee modulation,
how to construct the compliance framework for both producers and PROs,
the operational aspects of bonus/malus,
how to embed Ecomodulation in a competitive PRO landscape
and how the fee can be utilized as a tool to influence purchasing behaviour and stimulate sustainable product design.
The work of the task force is on-going, and the final results will be presented at an event in December 2021.
Issued 15 July 2021
A series of environmental NGOs call on the European Parliament to take measures to stop the sales and imports of illegal products via online marketplaces. In other to do so, they propose the following measures:
If no other actor located in the EU is liable to consumers, online marketplaces and fulfilment service providers must take full responsibility for the products of which they enable the sale. To this end, online marketplaces and fulfilment service providers must be actors in the supply chain by legal definition - for example as an importer.
Online marketplaces and fulfilment service providers must be subject to comprehensive due diligence obligations for the products for which they enable the sale. This includes, for example, checking that manufacturer, distributor and collector obligations are met.
Online marketplaces must show the full contact information of the EU actor, which is liable to consumers, and in the case of products subject to extended producer responsibility the manufacturer's registration number for the products of which they enable the sale.
EUCOLIGHT POSITION PAPER ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON A SINGLE MARKET FOR DIGITAL SERVICES (DIGITAL SERVICES ACT) AND AMENDING DIRECTIVE 2000/31/EC
EucoLight position paper addressing the responsibility of online marketplaces regarding non-compliant products.
Issued 3 May 2021
EucoLight commends the European Commission for its efforts to propose, with the Digital Services Act (DSA), new obligations on online companies to address concerns about illegal content. But there is room for improvement to address the responsibility of online marketplaces.
EucoLight main recommendations:
The DSA should distinguish the liability of online platforms, which offer products to consumers in the Union (online marketplaces), from that of other type of providers of intermediary services.
Online platforms, which offer products to consumers in the Union (online marketplaces), should perform compulsory ex-ante compliance checks, failing which they would bear the liability as producers of the products for which they facilitate the access to the consumer in the Union.
CORE MESSAGES FOR THE TRANSPOSITION OF ARTICLE 8a OF DIRECTIVE 2018/851 AMENDING DIRECTIVE 2008/98 ON WASTE
Issued 17 September 2020
In view of the transposition of Directive 2018/851, amending Directive 2008/98 on waste, by EU Member States, EUCOLIGHT, with some 15 years of experience on extended producer responsibility (EPR) in the Waste Electrical and Electronic Equipment (WEEE) lighting sector, and with EPR organisations as members in 19 different Member States, calls on national legislators to ensure that the transposition of Article 8a on general minimum requirements for extended producer responsibility schemes, leads to an efficient level playing field, reducing costs, boosting performance while reducing distortions in the waste market.
JOINT INDUSTRY COMMENTS ON MODULATING PRODUCERS' FINANCIAL CONTRIBUTIONS FOR WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT
Issued 25 July 2019
By the end of the year, the European Commission will publish guidelines on the modulation of financial contributions of producers of products to extended producer responsibility (EPR) schemes to assist Member States in the implementation of the Waste Framework Directive (WFD). The undersigning associations would like to provide policymakers with the following recommendations and key principles for a workable and successful modulation of producers’ fees.
EUCOLIGHT AND LIGHTINGEUROPE JOINT POSITION PAPER ON ECO MODULATION OF FEES IN WASTE FRAMEWORK DIRECTIVE (EU) 2018/851
Issued 16 July 2019
EucoLight and LightingEurope, as two EU wide trade associations with unique insight into the lighting industry, have prepared this position paper to consider how modulated fees might be applied to lamps and to luminaires.
POSITION PAPER ON THE PUBLIC CONSULTATION ON THE EU PRODUCT POLICY FRAMEWORK CONTRIBUTING TOWARDS A CIRCULAR ECONOMY
Issued 25 January 2019
EucoLight answers the public consultation, noting the lack of necessary questions about implementation, emphasizing that Extended Producer Responsibility is the best policy option for the management of waste and calling for improving legislation in several issues.
Issued 5 September 2018
EucoLight and other organisations express their concern on the impact on plastics recycling and the Circular Economy objectives of setting a disproportionately low unintentional trace contaminant (UTC) threshold (10 mg/kg) for decaBDE in Annex I of the POP Regulation.
EUCOLIGHT AND LIGHTINGEUROPE JOINT DEFINITIONS RELEVANT TO WEEE: 'LAMPS, LUMINAIRES & OTHER ELECTRICAL EQUIPMENT'
Issued 18 May 2018
EucoLight and LightingEurope publish simple joint definitions on lamps, luminaires and other electrical equipment to achieve clarity and legal safety for lighting products from registration until treatment, and to support stakeholders with compliance scheme handling.
Issued 08 November 2017
EucoLight comments on the Presidency Compromise Proposal for Changes to the Council Position (COREPER 18 October) and draws the attention of the representative of the negotiators on some specific points related to Extended Producer Responsibility.
Issued 1 August 2017
The event, organized jointly by WEEE Forum and EucoLight, will take place on the 13 September 2017 in Brussels.
Issued 16 May 2017
EucoLight is actively promoting a policy environment that allows a level playing for its members. In this statement, EucoLight highlights express concerns associated with sales on online platforms in regards to Extended Producer Responsibility (EPR).
Issued 20 March 2017
After the European Parliament adopted its position on the Waste Legislative Package, EucoLight offers a recommendation to Member States to secure the Extended Producer Responsibility requirements at European level.
Issued 13 January 2017
EucoLight essential key points to be addressed on the Waste legislative package.
IMPLEMENTING REGULATION ON THE CALCULATION OF WEIGHT OF EEE POM AND QUANTITY OF WEEE GENERATED IN EACH MEMBER STATE
Issued 23 December 2016
EucoLight comments on the new Draft Implementing Regulation released on 6 December 2016.
IMPLEMENTING REGULATION ON THE CALCULATION OF WEIGHT OF EEE POM AND QUANTITY OF WEEE GENERATED IN EACH MEMBER STATE
Issued 7 November 2016
EucoLight provides input for a future Implementing Regulation on the calculation of weight of EEE POM and quantity of WEEE generated in each Member State.
Issued 11 October 2016
EucoLight proposes compromise amendments.
Issued 28 September 2016
EucoLight comments on the amendments tabled by the members of the Committee on Environment, Public Health and Food Safety (ENVI) of the European Parliament.
Issued 24 June 2016
EucoLight commands the rapporteur of the Committee on Environment, Public Health and Food Safety (ENVI) of the European Parliament (Ms Simona Bonafè) for sharpening the minimal requirements for the Extended Producer Responsibility and makes amendments proposals on several points.
Issued 10 June 2016
EucoLight welcomes the draft opinion of the Committee on Industry, Research and Energy Comments (ITRE) of the European Parliament and emphasises some important aspects.
Issued 19 May 2016
EucoLight states its position.
and makes concrete amendments suggestions to the Commission proposal.
Issued 10 March 2016
EucoLight welcomes the introduction minimum requirements for Extended Producer Responsibility schemes at EU level and formulates recommendations for further clarification of certain crucial aspects.
Issued 7 August 2015
A circular economy offers us the possibility to live in a sustainable society. Extended Producer Responsibility (EPR) schemes make a significant contribution in transforming the economy. In this document, EucoLight makes proposals on how to improve EPR schemes in Europe.
Issued 3 July 2016
In this open letter, EucoLight supports the Parliament’s report and especially the inclusion of clear minimum standards for extended producer responsibility schemes as a mean to ensure transparency and cost effectiveness for extended producer responsibility schemes