NVMP-standpunt t.a.v. berekening PoM EEE en WEEE Generated

maandag 18 mei

Op 20 mei a.s. organiseert de Europese Commissie een stakeholdersbijeenkomst over de 'draft regulation establishing a common methodology for the calculation of the weight of EEE placed on the national market as well as for the calculation of the quantity of WEEE generated by weight in each Member State'.

Het standpunt van Vereniging NVMP ten aanzien van de 'draft regulation establishing a common methodology for the calculation of the weight of EEE placed on the national market as well as for the calculation of the quantity of WEEE generated by weight in each Member State' is als volgt.

Our general view is that the UNU’s ‘apparent consumption methodology’ approach cannot be used as there are enormous anomalies compared with what we know in e.g. NL. We would defend a position that in countries where a mature (set of) system(s) is in place with a properly functioning register, PoM should be established based on the data in the register.

We wish to express concerns about the accuracy of UNU’s approach as the outcome of this calculation shows significant discrepancies compared with the data that were gathered in the 15 years of the Dutch compliance scheme.

For example:
Consumer Electronics cat. 4
2013 PoM acc. to Wecycle 22,282 tonnes
2013 PoM acc. to UNU 42,607 tonnes

2013 difference 20,325 tonnes
2013 This would mean we missed almost 50% of the EEE PoM.

Statements from producers in 2013 continue the trend from the years 1999-2012 and, based on that long data series, present no reason for distrust.
The statements from the period 1999-2012 formed no problem whatsoever for the producers, because there were no associated cost consequences for them (as the disposal levy had already been imposed).
The statements, including those for 2013, were verified by accountants (always for the large participants and at random for the others).
The figures were compared to those from other sources, in this case the GfK reports. The results from this comparison reveal/revealed no significant differences.
So: particularly for TVs there is no reason to adjust the quantities registered by Wecycle.

The proportion of small brown waste in PoM category 4 grew from 21% to nearly 40% between 2006 and 2014 (ever lighter flat panel displays).
Given that no difference can be explained by the quantity of TVs, the difference must therefore come from the small brown waste (audio systems, digital cameras, DVD players).
Audio gear is becoming ever smaller (the large systems are ‘out’), DVD players and similar devices are no longer being sold (much more streaming and subscription services) and digital still cameras do not contribute to greater weight.
So: the difference to be explained of over 20 million kilos cannot be explained by the proportion of small brown goods.

An active search has been made for free riders; certainly for CE cat. 4, there is an accurate picture of the market, and it may be stated that no significant free rider problem exists. With over 230 participants who make CE brown goods statements, the market is essentially 100% covered. Free riders are only found sporadically, and this never has any relevant impact on the PoM. So: the difference cannot be explained by missing statements from free riders.