For several years Danish and European producers have requested a harmonisation of the producer responsibility registers in view of administrative relief. However, the companies have only recently realised that their reports often go through different commercial service providers before data are submitted to the national registers – for instance through collective schemes or consultants.
Producers often see several reporting procedures in one and the same country, for instance monthly and quarterly reporting etc. Therefore, a genuine administrative relief will require harmonisation of the reporting policy of the commercial players, if the producers are to reap the benefits of a harmonisation.
In connection with the revision of the WEEE Directive, industry called for the establishment of one overall EU producer responsibility register. This did not happen, however, and as a compromise industry suggested the introduction of the ”Appointed Representative (AR)” concept as it is known from other EU directives.
This AR will be the local representative of the producer towards all EU Member States as an alternative to the legislation so far under which the producer must have a national representative in each Member State.
However, the Directive states that this AR must be a legal unit in the Member State in question. In practice this means that the administrative burdens on industry have not been relieved; they have merely been replaced by new national administrative burdens.
EWRN efforts for a harmonisation of the producer responsibility and an outline of other national registers are found on www.EWRN.org
Suggestions and input for the work of this network are welcome. Please contact us on tel: +45 33779195 or firstname.lastname@example.org
See also new descriptions of all producer responsibility schemes in the EU commissioned by the EU Commission and carried out by Bio-Intelligence Service. Website of the consortium: Sustainable Management of Resources