The European Electronics Recyclers Association (EERA) has released a position paper highlighting the unfairness of the use of substantiated estimates. EERA recommends that Member States should be restricted in the continued use of substantiated estimates and a definitive timeline set out for them to be eliminated.
In the WEEE Directive (Article 16, paragraph 4) it states: “Member states shall collect information, including substantiated estimates, on annual basis, on the quantities and categories of EEE placed on their markets, collected through all routes, prepared for re-use, recycled and recovered within the Member State, and on separately collected WEEE exported by weight.”
EERA believes that these substantiated estimated volumes are affecting the proper collection, logistics and treatment of WEEE. Informal collections/recycling volumes are 34% of the EU total. These substantiated estimated volumes are often based on analysis of the input material of large shredders.