Urgent action alert! Subject: Urgent help to defend EU takeback initiative

Greetings-We need your immediate assistance to help defend an important new initiative that will help clean up the life cycle of computer manufacturing and also help solve the growing crisis of excessive electronic junk. This new directive from the European Union on Waste from Electrical and Electronic Equipment (WEEE) is under attack from U.S. based electronics firms and is in danger of being significantly weakened before it can even be implemented.

The "take back" initiative establishes Extended Producer Responsibility (EPR) which places legal and financial responsibility on the producers of electronic and electrical goods throughout the life cycle of their products - from design through the end-of-life. This initiative will not only encourage recycling but also push for CLEAN PRODUCT DESIGN. Some large manufacturers are lobbying to avoid the life cycle responsibilities and are trying to externalize the costs of recycling to consumers and municipalities. We have been asked by our allies in Europe to help protect the directive.The European directive, if implemented, will set the global standard for Extended Producer Responsibility, since all producers would have to design new products to meet the standard if they want to do business in Europe. It will be voted on this Spring by the Commission and then it will move to Parliament.

We need you to send a letter right now, however, since there is a very strong lobbying effort by industry to stop this landmark initiative. We have heard reports that most of the industry lobbyists are fighting against two important components of the initiative-the section that makes the producer financially responsible for the take back, and the phase-out of toxic materials (like PCBs, specific endocrine disrupting chemicals, etc.)

For additional background on this issue, you can find a copy of the draft directive on our website. You can also view the position of our allies the European Environmental Bureau (EEB) on their web page.

Please take a few minutes to fax or send letters on your own letterhead to the 3 commissioners listed below. Use the enclosed text as a model. Please also send (or e-mail) us a copy and we will add your name to our website showing the international support for this initiative. Thanks very much for your support.

Mr. J. Currie
Director General DG XI
European Commission
Rue de la Loi 200
Brussels B-1049 Belgium
Fax: +32 2 299 0310

Mr. Martin Bangemann
EU Commissioner for Industrial Affairs
Rue de la Loi 200
Brussels B-1049 Belgium
Fax: +32-2-295-5637

Dear Ms Bjerregaard, Mr. Currie, and Mr. Bangemann:

We support the European Union (EU) initiatives on Producer Responsibility, particularly the current proposed draft Directive on Waste from Electrical and Electronic Equipment. A good final directive will have international benefits since it will encourage similar Clean Production initiatives outside Europe, particularly within the United States.

We understand the EU is finalizing the draft text this Spring and we want to particularly emphasize the need to uphold the following three main points:

First, we are in complete agreement with you that the producer or distributor of all electronic products and electrical equipment must be financially responsible for managing the product at the end of its life. This is because only the producer has control over the design of a product. We do not believe local authorities or the public at large should have to pay for waste management costs of electrical and electronic equipment because we as consumers have no participation in the decision making process at the product design stage. Proposals that place the costs of waste management on local authorities require that local taxpayers have to pay not only for the product but also for the costs of managing the hazardous materials that producers choose to use within their products such as PVC plastics, flame retardants, lead, and other hazardous materials. We believe that placing the financial responsibility for take-back on the producer will encourage better product design such as durability, repairability and cleaner material use.

Second, we strongly support the current requirement of the European Commission to ensure, as a minimum, the phase out of brominated flame retardants, cadmium, lead, mercury and hexavalent chromium within electronic products. These chemicals are highly hazardous and persistent in the environment, are a known health danger and some are even acknowledged hormone disrupting chemicals. The use of these chemicals in domestic products must be phased out as a priority. Only this will help to clean up the entire product chain and help to alleviate worker health problems within the electronic industry as well as to reduce these hazardous emissions to the environment upon disposal. However this is only a beginning and we ask that the Commission include PVC plastic and all Halogenated materials for phase out as well. The goal of this directive should be the elimination of all carcinogenic, toxic and endocrine disrupting chemicals in electronic and electrical equipment.

Third, we agree with the draft text that incineration or energy recovery from incineration is not considered reuse or recycling. We oppose the use of incineration as a possible disposal route for end of life electrical and electronic waste. We believe that producers should first design products for durability and upgradability, thus reducing the flow of materials from resource use to final end of life. Recycling of materials at the end of a product's life must eventually cause no harm to worker health or the environment, hence the need for toxic-free materials within the product. We note that the first draft directive had no inclusion of incineration as a possible disposal route but now this has been reinstated as a possibility for 10 to 30 percent of electronic scrap for some products. We urge the Commission to re-instate the previous exclusion of all incineration.

Yours sincerely,

Ted Smith, International Campaign for Responsible Technology, USA
Leslie Byster, Silicon Valley Toxics Coalition, USA
Wanda Ballentine, Citizens for Public Accountability, USA
Richard Lowerre, Henry, Lowerre, Johnson & Frederick, USA
Beverly Thorpe, Clean Production Action, Canada
Mary Lehman, USA
Sharon Westmoreland, Partnership Architecture, USA
Michael Stanley-Jones, Green Party--Santa Clara County, USA
James E. Hardy,  Environmental Concerns of  Students, USA
Eric Drayer, New Mexico, USA
David L. Stitzhal, Board of Directors, Rainier Chamber of Commerce, USA
Stephane Gingras, Great Lakes United, Canada
Eremete Realacci, Legambiente, Italy
Hanna Martinpuro, International Coordinator, Finnish Association for Nature Conservation, Finland
Erja Heino, Waste Prevention Coordinator Finnish Association for Nature Conservation, Finland
Gavin McCall, European Project Manager, Friends of the Earth,  Scotland
Josette Benard, President, CREPAN, Comite Regional d'Etude pour la Protection et l'Amenagement de la Nature, France
Wilma Berends, Director Campaign Resources, Friends of the Earth, Netherlands
Betsy Taylor, Center for  a New American Dream, USA
Dr. Volker Strubel, Oeko-Institut, Freiburg, Germany
Jose M. Lercs, FEG, Federacion Ecoloxista Galega, Spain
Jacob Hartmann, Greenpeace-Denmark,
Itaca, Spain
Euan Armstrong, West Lothian, Scotland
Henk Blaauwgeers, SNM, Stichting Nature en Millieu, The Netherlands
Stuart Sontier, FAIR New Zealand, New Zealand
Dr. Willem H. Vanderburg, Director, Centre for Technology and Social Development, University of Toronto, Canada