01/04/2026

Harmonisation of scope 

Ahead of the upcoming revision of the WEEE Directive, as part of the Circular Economy Act, which is expected to amend the scope of the Directive, WEEE Forum is publishing a new paper. One of the issues with the current Directive is the lack of harmonisation across Member States: different national transpositions define the scope of electrical and electronic equipment (EEE) differently, creating inconsistencies in reported data on products placed on the market and collected, as well as disparities in EPR obligations. To ensure a level playing field for producers and more reliable data at EU level, the revised legislation should introduce clear, harmonised criteria for determining which products fall within scope and how they are classified. 

Any changes to the WEEE Directive scope should be subject a thorough impact assessment. Given the fast pace of technological change and the emergence of new product types, the EU should carry out a structured review at least every 3 years to determine whether new products should be added. 

As for photovoltaic (PV) panels, only a few Member States currently report them separately, and placing them within category “large equipment” has led to practical challenges, particularly for EPR. A dedicated PV panel category would help ensure clearer reporting, fairer producer obligations, and more effective waste management. 

Another issue concerns “pervasive electronics”, items such as clothing with sensors or furniture with built-in lighting or sound systems. Some countries classify these products as EEE, but they are rarely collected or treated as WEEE because they do not resemble traditional e-waste and do not fit established collection systems. Although the electronic components are small, they still pose environmental risks if not properly managed. These products should therefore fall under their main product legislation, e.g. textiles, furniture, while ensuring that their electronic parts are removed and properly treated at end of life. 

Implications of changes to the scope on treatment of WEEE 

Any changes to the WEEE scope will also affect waste treatment and collection systems, therefore their impacts should be assessed. If the new legislation sets targets per WEEE category, the categories should align with meaningful groupings facilitating the calculation and achievement of collection targets. 

Robust and consistent enforcement and clear communication are essential to ensure that producers of products newly added to the scope meet their responsibilities without shifting the burden onto existing producers. Adequate transition time will be necessary for adapting collection systems, and tools such as the WEEE calculation methodology must be regularly updated. 

Finally, the different material compositions and treatment needs of new products must be reflected in revised recycling and recovery targets. 

Discover more in the issue paper