Pöördumine

1

Subject: Call to reject the Commission’s proposal on the new own resource on based on

non-collected e-waste

To:

Presidency of the Council of the EU

General Affairs Council

Members of the European Parliament

Cc:

Members of the Council Working Party on Own Resources

Members of the Ad hoc Working Party on the MFF

Date: 21 May, 2026

Dear Representatives of the Member States,

Dear Members of the European Parliament,

On behalf of the electrical and electronic equipment (EEE) industry, we are writing to express our

profound concern regarding the European Commission’s proposal to introduce a new category of

EU own resources in the form of uniform call rate to the weight of non-collected electrical and

electronic equipment amounting to €2/kg (referred in this letter as “e-waste levy”), as set out in

the draft Council Decision on new Own Resources1.

We consider this measure to be fundamentally flawed. It risks leading to significant market

fragmentation and imposing disproportionate financial and administrative burdens, while lacking

a robust and harmonised data foundation. For these reasons, we strongly urge that the

proposed e-waste levy be rejected.

The proposed e-waste levy may appear to be a simple and environmentally sound solution, but

its reliance on national implementation will create several serious issues. The measure

follows a design similar to the contribution from Member States based on non-recycled plastic

packaging waste (referred in this letter as “plastic tax”) introduced under the previous Multiannual

Financial Framework. It would be added on top of an already well-established policy framework

set out in EU environmental legislation, notably the Waste Electrical and Electronic Equipment

(WEEE) Directive. Mirroring the introduction of a uniform call rate applies to the weight of not

recycled plastic packaging waste (“plastic tax” approach, which was introduced in addition to

existing EU packaging waste frameworks), raises grave concerns about the impacts of

implementation:

● Unreliable data

1 Proposal for a Council Decision on the system of own resources of the European Union and repealing Decision (EU, Euratom)

2

Statistical data, such as Eurostat’s current data on e-waste recycling and collection rates, are far

from reliable, as acknowledged by the EU itself2 and pointed out by stakeholders like the WEEE

Forum3.

Figures for some Member States are unverified estimates that lack a consistent methodology.

This disparity makes it impossible to implement the own resource fairly, risking the penalisation

of countries or producers based on flawed or incomparable metrics. Furthermore, the method

proposed in the draft Council Decision calculates "missing" e-waste by applying the widely

challenged 3-years POM calculation methodology (see above). This methodology is likely to be

amended with a planned new WEEE policy framework.

Because the actual amount of e-waste generated by consumers each year is an unknown

variable, any such calculation is inherently uncertain. The proposal also assumes that uncollected

e-waste is synonymous with improperly disposed e-waste, overlooking the significant portion of

electronics that are exported before becoming waste or that remain in consumers' hands.

Consumers frequently hoard devices for reasons such as data privacy or future repair, and until

a product is discarded, it is not legally considered waste.

● Questionable environmental incentives

The European Commission proposes that the measure will deliver positive environmental

outcomes and support strategic autonomy by incentivising waste reduction and collection.

However, we are not aware of any impact assessment that substantiates these expected benefits.

The measure tries to serve both as an environmental incentive and a stable revenue source, but

these goals are inherently incompatible: if it works environmentally, revenues will shrink; if

revenues remain high, it means behavior is not changing. As designed, it is therefore either fiscally

unreliable or environmentally ineffective, effectively turning ongoing regulatory failure into a

permanent source of EU funding4.

Moreover, if passed onto economic operators, it risks producing the opposite effect by

discouraging investment in waste management and recycling infrastructure, thereby undermining

the EU’s circular economy objectives. As a significant share of e-waste remains uncollected due

to consumer behaviour, EU policy should instead focus on encouraging longer product use

through repair, reuse, and refurbishment. The proposed measure fails to address these

underlying behavioural causes.

● Increase of consumer costs

The proposed new own resource category is formally levied on Member States and the Council

Decision does not specify how they should finance it. It is likely, that the cost will be passed on

2 Evaluation of the WEEE Directive, European Commission 3 Towards more meaningful and robust WEEE management targets, WEEE Forum 4 An alternative EU budget. How to Build a Better MFF Around the Single Market, EPICENTER

3

through higher compliance costs and extended producer responsibility (EPR)5 as occurred with

plastic tax. This, in turn would lead to the increase of costs by Producer Responsibility

Organisations (PROs) and producers of electrical and electronic equipment (EEE). This would

ultimately lead to higher costs for consumers. Under existing EU legislation (notably the WEEE

Directive), producers already bear financial responsibility for the collection, treatment, and

environmentally sound disposal of e-waste through PROs, costs which are already reflected in

the product prices paid by consumers. Passing the proposed levy onto producers or PROs would

introduce an additional consumption-based charge on essential electrical and electronic products,

disproportionately affecting consumers with lower purchasing power.

• Single Market barriers and fragmentation

In line with the existing EU regulatory framework, manufacturers of EEE are already responsible

for their products throughout their entire lifecycle. Introducing this levy on top of the current

framework risks creating a fragmented landscape of national rules and tax rates across the EU.

Experience with the “plastic tax” has shown that its implementation resulted in a patchwork of

uncoordinated national and regional approaches, requiring significant effort from businesses -

particularly those operating in multiple Member States - to understand and comply with divergent

systems6. Such fragmentation creates barriers within the Single Market and generates additional

administrative and financial burdens, running counter to the EU’s broader objectives of regulatory

simplification and market harmonisation.

● Regulatory overlap

Introducing the levy ahead of the Circular Economy Act (CEA), which is expected to be presented

in Q3 2026 to revise the WEEE Directive (likely changing the methods used for the calculation of

the WEEE collection rate), risks creating regulatory overlap, inconsistencies and double

regulation. Proceeding with a new levy in parallel and advance of this broader reform would be

premature and could undermine the coherence of the EU regulatory framework.

● Persistent legal ambiguity

The e‑waste levy risks becoming a permanent source of uncertainty for industry. Because

Member States retain full discretion over its financing, there is profound unpredictability regarding

the timing and mechanism by which these costs might be passed on, as clearly demonstrated

during the rollout of the plastic levy. Such a lack of clarity significantly disrupts strategic investment

and long-term financial planning.

In light of the above, we urge to reject the proposed e‑waste levy.

We stand ready to work constructively with policymakers and relevant stakeholders to identify

effective and proportionate solutions that genuinely advance the circular economy, without

penalising European consumers or undermining Europe’s industrial base.

Yours sincerely,

5 An alternative EU budget. How to Build a Better MFF Around the Single Market, EPICENTER 6 Plastic Taxation in Europe 2025, WTS Global

4

APPLiA

CCIA Europe

Digital Europe

EPTA

EUCOBAT

EucoLight

European Garden Machinery Federation

European Recycling Platform

ITI

LightingEurope

Orgalim

PRONEXA

WEEE Forum

1

Subject: Call to reject the Commission’s proposal on the new own resource on based on

non-collected e-waste

To:

Presidency of the Council of the EU

General Affairs Council

Members of the European Parliament

Cc:

Members of the Council Working Party on Own Resources

Members of the Ad hoc Working Party on the MFF

Date: 21 May, 2026

Dear Representatives of the Member States,

Dear Members of the European Parliament,

On behalf of the electrical and electronic equipment (EEE) industry, we are writing to express our

profound concern regarding the European Commission’s proposal to introduce a new category of

EU own resources in the form of uniform call rate to the weight of non-collected electrical and

electronic equipment amounting to €2/kg (referred in this letter as “e-waste levy”), as set out in

the draft Council Decision on new Own Resources1.

We consider this measure to be fundamentally flawed. It risks leading to significant market

fragmentation and imposing disproportionate financial and administrative burdens, while lacking

a robust and harmonised data foundation. For these reasons, we strongly urge that the

proposed e-waste levy be rejected.

The proposed e-waste levy may appear to be a simple and environmentally sound solution, but

its reliance on national implementation will create several serious issues. The measure

follows a design similar to the contribution from Member States based on non-recycled plastic

packaging waste (referred in this letter as “plastic tax”) introduced under the previous Multiannual

Financial Framework. It would be added on top of an already well-established policy framework

set out in EU environmental legislation, notably the Waste Electrical and Electronic Equipment

(WEEE) Directive. Mirroring the introduction of a uniform call rate applies to the weight of not

recycled plastic packaging waste (“plastic tax” approach, which was introduced in addition to

existing EU packaging waste frameworks), raises grave concerns about the impacts of

implementation:

● Unreliable data

1 Proposal for a Council Decision on the system of own resources of the European Union and repealing Decision (EU, Euratom)

2

Statistical data, such as Eurostat’s current data on e-waste recycling and collection rates, are far

from reliable, as acknowledged by the EU itself2 and pointed out by stakeholders like the WEEE

Forum3.

Figures for some Member States are unverified estimates that lack a consistent methodology.

This disparity makes it impossible to implement the own resource fairly, risking the penalisation

of countries or producers based on flawed or incomparable metrics. Furthermore, the method

proposed in the draft Council Decision calculates "missing" e-waste by applying the widely

challenged 3-years POM calculation methodology (see above). This methodology is likely to be

amended with a planned new WEEE policy framework.

Because the actual amount of e-waste generated by consumers each year is an unknown

variable, any such calculation is inherently uncertain. The proposal also assumes that uncollected

e-waste is synonymous with improperly disposed e-waste, overlooking the significant portion of

electronics that are exported before becoming waste or that remain in consumers' hands.

Consumers frequently hoard devices for reasons such as data privacy or future repair, and until

a product is discarded, it is not legally considered waste.

● Questionable environmental incentives

The European Commission proposes that the measure will deliver positive environmental

outcomes and support strategic autonomy by incentivising waste reduction and collection.

However, we are not aware of any impact assessment that substantiates these expected benefits.

The measure tries to serve both as an environmental incentive and a stable revenue source, but

these goals are inherently incompatible: if it works environmentally, revenues will shrink; if

revenues remain high, it means behavior is not changing. As designed, it is therefore either fiscally

unreliable or environmentally ineffective, effectively turning ongoing regulatory failure into a

permanent source of EU funding4.

Moreover, if passed onto economic operators, it risks producing the opposite effect by

discouraging investment in waste management and recycling infrastructure, thereby undermining

the EU’s circular economy objectives. As a significant share of e-waste remains uncollected due

to consumer behaviour, EU policy should instead focus on encouraging longer product use

through repair, reuse, and refurbishment. The proposed measure fails to address these

underlying behavioural causes.

● Increase of consumer costs

The proposed new own resource category is formally levied on Member States and the Council

Decision does not specify how they should finance it. It is likely, that the cost will be passed on

2 Evaluation of the WEEE Directive, European Commission 3 Towards more meaningful and robust WEEE management targets, WEEE Forum 4 An alternative EU budget. How to Build a Better MFF Around the Single Market, EPICENTER

3

through higher compliance costs and extended producer responsibility (EPR)5 as occurred with

plastic tax. This, in turn would lead to the increase of costs by Producer Responsibility

Organisations (PROs) and producers of electrical and electronic equipment (EEE). This would

ultimately lead to higher costs for consumers. Under existing EU legislation (notably the WEEE

Directive), producers already bear financial responsibility for the collection, treatment, and

environmentally sound disposal of e-waste through PROs, costs which are already reflected in

the product prices paid by consumers. Passing the proposed levy onto producers or PROs would

introduce an additional consumption-based charge on essential electrical and electronic products,

disproportionately affecting consumers with lower purchasing power.

• Single Market barriers and fragmentation

In line with the existing EU regulatory framework, manufacturers of EEE are already responsible

for their products throughout their entire lifecycle. Introducing this levy on top of the current

framework risks creating a fragmented landscape of national rules and tax rates across the EU.

Experience with the “plastic tax” has shown that its implementation resulted in a patchwork of

uncoordinated national and regional approaches, requiring significant effort from businesses -

particularly those operating in multiple Member States - to understand and comply with divergent

systems6. Such fragmentation creates barriers within the Single Market and generates additional

administrative and financial burdens, running counter to the EU’s broader objectives of regulatory

simplification and market harmonisation.

● Regulatory overlap

Introducing the levy ahead of the Circular Economy Act (CEA), which is expected to be presented

in Q3 2026 to revise the WEEE Directive (likely changing the methods used for the calculation of

the WEEE collection rate), risks creating regulatory overlap, inconsistencies and double

regulation. Proceeding with a new levy in parallel and advance of this broader reform would be

premature and could undermine the coherence of the EU regulatory framework.

● Persistent legal ambiguity

The e‑waste levy risks becoming a permanent source of uncertainty for industry. Because

Member States retain full discretion over its financing, there is profound unpredictability regarding

the timing and mechanism by which these costs might be passed on, as clearly demonstrated

during the rollout of the plastic levy. Such a lack of clarity significantly disrupts strategic investment

and long-term financial planning.

In light of the above, we urge to reject the proposed e‑waste levy.

We stand ready to work constructively with policymakers and relevant stakeholders to identify

effective and proportionate solutions that genuinely advance the circular economy, without

penalising European consumers or undermining Europe’s industrial base.

Yours sincerely,

5 An alternative EU budget. How to Build a Better MFF Around the Single Market, EPICENTER 6 Plastic Taxation in Europe 2025, WTS Global

4

APPLiA

CCIA Europe

Digital Europe

EPTA

EUCOBAT

EucoLight

European Garden Machinery Federation

European Recycling Platform

ITI

LightingEurope

Orgalim

PRONEXA

WEEE Forum