01/04/2026

The WEEE Forum’s issue paper discusses the challenges faced by islands, island states, and small territories in implementing the WEEE Directive, particularly regarding the EPR. These regions experience higher relative costs, logistical constraints, and disproportionate administrative burdens due to small market size, geographical isolation, and limited treatment infrastructure. 

In the context of this paper, “small states, island states and states with operations on islands” are understood to include Malta, Luxembourg, Cyprus, Georgia, Macedonia, Bosnia Herzegovina, Moldova, Greece, Italy, Spain, France, Portugal, Croatia, Sweden, Denmark, Finland, Iceland, Ireland, Estonia, United Kingdom, and the Netherlands. 

Distinct features of WEEE EPR systems in islands and small countries 

• Most electrical and electronic equipment (EEE) is placed on the market by importers and online sellers, creating weak connections to manufacturers and complicating compliance. Many producers place very small volumes on the market, increasing administrative complexity. Online marketplaces and the authorised representative (AR) system add further complexity, especially for small importers. 

• Lack local WEEE treatment capacity therefore most waste must be exported, which significantly increases cost, storage needs, administrative workload, and delays due to waste shipment notifications. It is likely to be complicated further by changes in the classification of WEEE as hazardous waste in the Basel Convention. As a result, WEEE is sometimes incorrectly treated as scrap to avoid costlier compliant handling.  

• Administrative burdens on PROs increase when multiple PROs operate in the same area, creating competition that can reduce overall activity and lead to uneven sharing of rural collection and communication costs. Because WEEE volumes are too low to justify dedicated infrastructure, these markets face additional structural challenges. Cherry-picking of valuable and easily collectable WEEE becomes more common, further distorting competition and undermining balanced system performance. 

• Significant share of WEEE is generated by temporary users, such as tourists and crossborder workers. They buy electrical products in a territory but often dispose of them elsewhere, which artificially lowers that territory’s WEEE collection rates. This distortion is especially significant in small territories, yet no data is collected to measure its real impact. High levels of construction activity also generate additional WEEE, which has a proportionally greater effect in small territories compared to larger countries.  

Recommendations 

Overall, the WEEE Forum recommends administrative simplification, harmonisation of AR process on the EU level, infrastructure investments, and improved enforcement to ensure a level playing field and effective EPR in small and island territories, namely: 

• Consider introducing grants, public service obligation or other financial measures aimed at balancing additional costs on the shipment of WEEE should be considered.  

• Allow measures for simplifying disproportionate administrative burden e.g., exemption of national (advanced) eco-modulation criteria, simplified reporting for small producers, special management of online marketplaces, simplified/fast track waste notification processes etc. 

• Harmonise authorized representative procedure on EU level.

 

Discover more in the issue paper