EU & Cyprus Legal Framework and Management of WEEE

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EU & Cyprus legal framework and management of WEEE

By Marios Demosthenous University of Nicosia, Cyprus

On behalf of the educational NGO CARDET

November 2016

Edited by Iris Charalambidou University of Nicosia, Cyprus

The report was compiled for the purposes of the European project “Time for change: Promoting sustainable consumption and production of raw materials in the context of European Development Year 2015 and beyond!” As WEEE holds vast quantities of raw and rare raw materials, an investigation for the management practices of WEEE in Europe and Cyprus was essential. The strengths and weaknesses of the Industry are identified and recommendations can be made for the sustainability of the EEE and WEEE industry.

This document has been produced with the financial assistance of the European Union. The contents of this document] are the sole responsibility of CARDET and can under no circumstances be regarded as reflecting the position of the European Union.

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Table of Contents

Abbreviations and acronyms………………………………………………………………………...... 4 Acknowledgments...... 4 Introduction ………………………………………………………………………………………………………………………...... 5 Waste of Electrical and Electronic Equipment (WEEE) ………………………………………………………….6 Legislation on WEEE …………………………………………………………………………….………………………..7 European Union Legislation ……………………………………………………………………………………………...... 7 Waste Framework Directive (2008/98/EC)…………………………………………………………………………………...... 7 Regulation on Shipment of Waste (EU/2016/1245) …………………………………………………………………….....9 RoHS Directive (2011/65/EC)..…………………………………………………………………………………………………...... 10 WEEE Directive (2012/19/EC).…………………………………………………………………………………………………...... 10 Overview of scope of WEEE Directive ……………………………………………………………………...... 10 Preparation for Re-Use ……………………………………………………………………………………………...... 12 Eco-design & interoperability in ……………………………………….………………………………...... 12 Standardisation systems for management of WEEE in Europe ……………………………………..13 Legislation in Cyprus ………………………………………………………………………………………………………....14 Management of WEEE in Cyprus ……………………………………..……………………………16 WEEE Electrocyclosis Cyprus Ltd …………………………………………………………………………………………………….16 Collection, sorting and treatment of WEEE …………………………………………………………………………………….17 Collection volumes of WEEE ……………………………………………………………………………………..…………………...21 Challenges in the management of WEEE ………………………………………………………………………………………..23 Not meeting collection targets ……………………………………………………………………………………………………..23 Limited inspection and enforcement capacities …………………………………………………………………………....27 Implementation and Enforcement of Environmental Law (IMPEL) …………………………………………...28 Countering WEEE illegal Trade (CWIT) ……………………………………………………………………………………...29 Basel Action Network (BAN) ……………………………………………………………………………………………………..29 ..Future recommendations …………………………………………………………………………………………………………….30 Conclusion ……………………………………..…………………………………………………………….31 List of References …………..…………………………………………………………………………….33

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Tables Table 1: EU and Cypriot legislation concerning electrical and electronic equipment …7 Table 2: The main principles of the Waste Framework Directive (2008/98/EC) ………...8 Table 3: Directive 2012/19/EC Recovery, Recycling, Re-Use Targets for 2015-2018 (EU- 10) ……………………………………………………………………………………………………………..11 Table 4: The reduced 6 categories and the targets for recovery re-use and recycling from 2019 (EU-6) ……………………………………………………………………………………….12 Table 5: Total volume of Waste Electrical and Electronic Equipment (WEEE) collected in the EU in 2013, by EEE category …………………………………………………………….....16 Table 6. The containers used by WEEE Electrocyclosis Cyprus Ltd for the collection of WEEE ………………………………………………………………………………………………………...17 Table 7: Categories of WEEE in relation to their future processing…………………………..19 Table 8: Companies housed at storing and processing facility in Geri, Nicosia ………...20 Table 9: The fate of WEEE collected in Cyprus ………………………………………………………...20 Table 10: Collected volume of WEEE in Cyprus in 2015 ……………………………………………..22

Figures Figure 1: EU Waste Management Pyramid …………………………………………………………….....8 Figure 2: Plastic boxes for WEEE collection ……………………………………………………………...17 Figure 3: Blue Plastic barrel ……………………………………………………………………………………...17 Figure 4: Skip containers hook ………………………………………………………………………………....17 Figure 5: KYKAN transportation Van for WEEE ………………………………………………………....19 Figure 6: Transboundary shipment of waste from Cyprus in 2013 …………………………....21 Figure 7: Incoming WEEE (Data collected from Electrocyclosis, 2016) ……………………...22 Figure 8: POM of EEE in Cyprus for the period 2010-2015 ………………………………………...23 Figure 9: (EEE) place on market and WEEE collected and treated, EU, 2007–13………...24 Figure 10: Total collection rate as a percentage of the average weight of EEE put on the market in the three preceding years 2010–12 …………………………………………….25 Figure 11: Questionnaire on implementation difficulties among member states ………..26 Figure 12: Evaluation of main difficulties by different stakeholders …………………………….26 Figure 13: High rate of selective picking and unaccounted collection ………………………….27 Figure 14: Limited inspection and enforcement capacities ………………………………………….28

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Abbreviations and acronyms

B2B: Business to Business B2C: Business to Consumer CFC/HCFC: Chlorofluorocarbon/ Hydrochlorofluorocarbon CRT: Cathode Ray Tubes EC: European Commission ES: Environmental Services EEE: Electrical and Electronic Equipment* IT: Information Technology LCD: Liquid Crystal Display LED: Light-emitting diode MANRE: Ministry of Agriculture and Natural Resources MS: Member States OEM: Original Equipment Manufacturer P2P: Peer to Peer PCB: Polychlorinated Biphenyl POM: Products placed On the Market PRO: Producer Responsibility Organisation - Distributors RC: Recycling Centres TV: Television WEEE: Waste Electrical and Electronic Equipment WEEELABEX: WEEE Label of Excellence WG: WEEE Generated WFD: Waste Framework Directive (2008/98/EC)

* EEE: “equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current”

Acknowledgments We would like to express our gratitude to all persons providing valuable information and data, comments and feedback for this study. Special thanks go to the team at CARDET, particularly Sotiris Themistokleous for the opportunity to work on this project, and to Theocharis Michail for his valuable suggestions and guidance. Grateful thanks also to Athena Papanastasiou from Department of Environment for providing data and information on the WEEE industry in Cyprus, as well as Irodotos Savva from Electrocyclosis and Giannos Virydes from Cyprus University of Technology.

Introduction This report aims to describe the major concerns and situation in Europe and Cyprus with regards to Waste of Electrical and Electronic Equipment (WEEE) and the challenges faced in terms of

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implementing a robust legislative framework. The first part of the report focuses on legislation and presents the key points of the important Directives and Regulations designed to tackle the ever increasing flow of Electrical and Electronic Equipment (EEE) that are Placed On Market (POM) and end of life equipment. The second part of the report focuses on the network of collection of WEEE in Cyprus and the challenges the industry is facing.

Waste of Electrical and Electronic Equipment (WEEE) WEEE such as computers, TV-sets, refrigerators and cell phones is one of the fastest growing waste streams in the EU, growing at 3-5 % per year (Eurostat, 2016a) with some 9 million tonnes generated in 2005, and expected to grow to more than 12 million tonnes by 2020 (European Commission, 2016a).

The forces that drive the volume of material being used in Electrical and Electronic Equipment (EEE) are the forces of the technological revolution. Modern society’s hi tech infrastructure and trends are driven by faster and cheaper microchip technology, resulting in an explosion of electronic consumer goods. Although technological innovation is responsible for swift advances in design and production of electronics, it has not yet extended to adequate responsibility for the environmental impacts of products, especially safe and effective end-of-life policies of EEE. The production of EEE is one of the fastest growing industries, leading to an increase in obsolescence and replacement of products thus resulting in an increasing volume of European WEEE every year. Compared to traditional waste streams, WEEE quantification and handling pose unique and complex challenges (MacKerron, 2011).

Furthermore, WEEE is a complex mixture of materials and components, many of which are hazardous. If not managed properly, they can cause major environmental and health problems. Moreover, the production of modern electronics requires the use of scarce and expensive resources. For instance, in 2014, 6.5% of worldwide gold production, 25% of silver and 38% of copper were used in electrical and electronic products (Thomson Reuters, 2016). Therefore, in order to improve the environmental management of WEEE and contribute to a circular economy, the improvement of collection, treatment and recycling of electronics is essential (European Commission, 2016a).

The global impact of the technological revolution has had a tremendous toll on resources, energy, the environment and local communities. Electrical and electronic equipment are constructed with minute amounts of a wide variety of metals and chemicals. This poses serious challenges during the process of recycling thus requiring a significant amount of energy. Recycling of the materials reduces the extraction of new resources and results in less CO2 emissions, while providing jobs for Member States through the WEEE management system. According to a study by the European Commission (EC), full implementation of EU waste legislation would save €72 billion a year, increase the annual turnover of the EU waste management and recycling sector by €42 billion and create over 400,000 jobs by 2020 (BIO Intelligence Service, 2011).

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Legislation on WEEE

European Union Legislation The amount of waste being created is increasing and the nature of waste itself is changing, partly due to the dramatic rise in the use of electronic products. This means waste now contains an increasingly complex mix of materials, including plastics, precious metals and hazardous materials that are difficult to deal with safely. EU waste management policies aim to reduce the environmental and health impacts of waste and improve Europe’s resource efficiency. The long-term goal is to turn Europe into a recycling society and achieve higher levels of recycling, and to minimise the extraction of additional natural resources by avoiding waste and using unavoidable waste as a resource wherever possible. Proper waste management is a key element in ensuring resource efficiency and the sustainable growth of European economies.

For an efficient recycling process to be successful without compromising the environment and public health, various factors have to be considered. In order to address these issues, the European Union has issued three directives and one regulation on waste (Table 1).

Table 1: EU and Cypriot legislation concerning electrical and electronic equipment

Name of EU Directive or Regulation Code Implementing Law in Cyprus 1. Waste Framework Directive 2008/98/EC Cyprus Waste Law (185(I)/2011) 2. Regulation on Shipments of Waste EC/1013/2006 Solid and EC/660/2014 Hazardous Waste EC/2016/1245 (revised) Law (215(I)/2002) 3. Directive on the Restriction of the Use of 2002/95/EC Regulation 68-204 certain Hazardous Substances in Electrical 2011/65/EC (revised) (Law 668/2004) and Electronic Equipment (RoHS) 4. Directive on Waste Electrical and Electronic 2002/96/EC Regulation 68-204 Equipment (WEEE) (Law 668/2004) 2012/19/EU (revised) Management of WEEE, Regulation 73/2015

1. Waste Framework Directive (2008/98/EC) The Waste Framework Directive (2008/98/EC) came into effect on 12 December 2010 and sets the basic concepts and definitions related to waste management, such as definitions of waste, recycling and recovery. It explains when waste ceases to be waste and becomes a secondary raw material (so called ‘end-of-waste criteria’), and how to distinguish between waste and by-products.

The Directive prescribes the main principles described below (Table 2) and sets the priority order with the waste management pyramid (see Figure 1).

Table 2: The main principles of the Waste Framework Directive (2008/98/EC)

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Principle of Best Available Technology (BAT) Disposal facilities must be equipped with the best available technology. In order to establish an integrated and adequate network of disposal installations, taking account of the best available technology and without involving excessive costs, cooperation with other Member States is advisable where necessary.

Principle of proximity Waste must be treated as close as possible to the place of production or collection.

Principle of Self-sufficiency The network must enable the Community as a whole to become self‑sufficient in waste disposal.

Polluter Pays Principle (PPP) Waste treatment facilities must be subsidised by the producer/polluter program.

The Directive also sets specific obligations on the Member States to ensure corporate governance. Every Member State must prepare a waste management plan which integrates local, regional and national needs. The Member State is responsible for control over the disposal facilities. A system of licenses must be introduced. Member States must install a monitoring and reporting system in accordance with the European guidelines.

Member States must ensure that records are kept on the amounts of materials entering and leaving treatment, recycling, and recovery facilities. The best available treatment, recycling, and recovery techniques must be used. Member States must also ensure that treatment facilities obtain all relevant permits from the appropriate authorities.

Figure 1: EU Waste Management Pyramid (Reprinted from European Commission, 2016b)

In addition to the ‘Polluter Pays Principle’, the Directive also introduces the ‘Extended Producer Responsibility’. Extended Producer Responsibility makes producers financially responsible once their products become waste, providing them with an incentive to develop products that avoid unnecessary waste and can be used in recycling and recovery operations. An example of producer responsibility is the ‘Green Dot’ system currently operating in many Member States. Producers placing material on the

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market pay a levy for the collection and recycling of a related amount of waste material. This forces them to consider the entire life cycle of the goods they produce. It also incorporates provisions on hazardous waste. Therefore, the Directive requires that Member States adopt waste prevention programmes in addition to waste management plans (European Commission, 2016b).

2. Regulation on Shipment of Waste (EU/2016/1245) The Regulation on Shipment of Waste (EU/2016/1245) concerns collected and categorised WEEE that are exported to be recycled. The Regulation adopts the Basel Convention and the revision of the OECD’s 2001 decision for the control of transboundary movements of hazardous waste destined for recovery operations.

The initial Regulation (EC/1013/2006) was revised on 15 May 2014 (EU/660/2014) to strengthen Member States inspection systems to regulate illegal shipments, and was revised again on 28 July 2016 (EU/2016/1245).

The European Union (EU) has a system to supervise and control shipments of waste within its borders as well as the countries of the European Free Trade Association (EFTA), the Organisation for Economic Cooperation and Development (OECD) and non-EU countries that have signed the Basel Convention. It lays down rules for controlling waste shipments in order to improve environmental protection.

The Regulation applies to shipments of waste:

● between EU countries within the EU or transiting via non-EU countries; ● imported into the EU from non-EU countries; ● exported from the EU to non-EU countries; ● in transit through the EU, on the way from or to non-EU countries. Trade bans

● Exports to non-EU countries of waste for disposal are prohibited, except to EFTA countries that are party to the Basel Convention. ● Exports for recovery of hazardous waste (i.e. that poses a risk to human health and the environment) are prohibited, except those directed to countries to which the OECD decision applies. Imports from non-EU countries of waste for disposal or recovery are prohibited, except for imports:

● from countries to which the OECD decision applies; ● non-EU countries that are party to the Basel Convention; ● countries that have concluded a bilateral agreement with the EU or EU countries; or ● other areas during situations of crisis. 3. RoHS Directive (2011/65/EC) The RoHS Directive (Directive 2002/95/EC) entered into force in February 2003. It requires heavy metals, such as lead(Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr (VI)) and flame retardants, such as polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) to be substituted by safer alternatives. The Directive was revised in 2011 (Directive 2011/65/EU) and became effective on 3 January 2013 (European Commission, 2016a).

4. WEEE Directive (2012/19/EC)

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The WEEE Directive (Directive 2002/96/EC) entered into force in February 2003 and provided for the creation of collection schemes of WEEE free of charge to consumers. The aim of the schemes was to increase the recycling and/or re-use of WEEE. In 2012, the Directive was revised (Directive 2012/19/EC), entering into force in August 2012. The revised Directive introduced a gradual increase in collection targets to be applied from 2016 up until 2019. The targets are based on import of EEE and collected volumes of WEEE, rather than on the total weight of collected WEEE divided by a country’s population, as was the case in the previous version of the Directive (European Commission, 2016a).

Overview of scope of WEEE Directive The objective of the WEEE Directive is to reduce the amount of WEEE that ends up in landfills. It is broad in scope, covering most EEE used by consumers or professionals that may otherwise end up in the municipal waste stream. This includes products sold in the EU from abroad and products sold online. An important provision of the Directive is the introduction of the ‘National Registry for Producers and Distributors’ which are solely responsible for financing the collection and treatment system of WEEE in each member state. The companies are obliged to report towards their respective countries Environment Services on their imported or produced EEE that is Placed On Market as well as towards national Statistical Services.

The Directive’s scope has been widened following its revision, and two implementation periods have been introduced that reflect this. A period of six years, from 13 August 2012 to 14 August 2018, is regarded as a transitional period for Member States to prepare for the new ‘open scope’ and increase the required re-use and recovery percentages (Table 3). During the transitional period the scope will remain identical to the scope of the former Directive, in terms of the 10 categories with the inclusion of photovoltaic panels. From the 14th of August 2018, further increase of recovery and re-use volumes will be applied and Member States are expected to reach the required percentages with the reduced categories of equipment (Table 4).

From 15 August 2018 onward, the revised Directive will extend its current restricted scope to an ‘open scope’. Any equipment which falls under the definition of EEE must be included in one of the six new categories, set out in Annex III of the revised Directive (Table 4). According to Seyring (2015), under the EU10 some WEEE were classified in different categories, although they were treated together and were subject to different recovery and recycling targets, thus making these volumes hard to track. The new ‘open scope’ will provide solutions to these issues and a clearer and easier estimation process on re-use, recycling and recovery volumes.

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Table 3: Directive 2012/19/EC Recovery, Recycling, Re-Use Targets for 2015-2018 (EU-10) (Reprinted from Seyring et al., 2015)

In addition, the revised Directive aims to limit the administrative burden of national authorities and increase consistency in data reporting among Member States. Member States are expected to report to the Commission at three-year intervals on the transposition and implementation of the Directive into their territories. The first report, covering the period February 2014 to December 2015 was due by September 2016.

Furthermore, new and ambitious collection targets are laid down in the revised Directive. As of 2016, the minimum collection rate of WEEE shall be 45 % of the average weight of EEE placed on the market during the three preceding years in that Member State. From 2019, the minimum collection rate to be achieved annually shall be 65 % of the average weight of EEE placed on the market in the three preceding years in the Member State concerned, or alternatively 85 % of WEEE generated on the territory of that Member State. The new targets aim to ensure improved collection of WEEE.

Table 4: The reduced 6 categories and the targets for recovery re-use and recycling from 2019 (EU-6) (Reprinted from Seyring et al., 2015)

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In order for the European Union to achieve its goals and regulate WEEE policy, Member States have to report to the European Commission on the achievement of the targets for WEEE collection, re-use, recycling and/or recovery on the basis of Commission Decision (2005/369/EC). Reported data is made available in the Eurostat database approximately three months after the reporting deadline. Currently, data is available from 2005 to 2013. Data for the reporting period 2014 was due by the end of June 2016 (Eurostat, 2016a).

Moreover, the revised Directive provides Member States with the tools to fight illegal shipments of WEEE more efficiently, and introduces implementing acts towards the harmonisation of registration and reporting requirements for EEE producers (Seyring et al., 2015).

Preparation for Re-Use In order to tackle the issue of re-use of whole appliances due to consumer preferences to ‘new and better’, there is a need to move from the linear model ‘produce, consume, throw’ to a circular economy, where ‘nothing is wasted, everything is transformed’. Many consumers still see used products as low quality products. At the same time, there is a lack of awareness of the availability of high quality, second hand equipment and on information where people can buy it. Cheap, new products available on the market also do not encourage consumers to buy second hand products. More than 70,000 tonnes of WEEE were reported by Member States to Eurostat as being re-used and prepared for re-use in the EU in 2012.

According to the EU waste hierarchy/pyramid, preparation for re-use is at the top of the pyramid because it ensures the product recovers its maximum potential, with a minimum use of resources. Yet the revised WEEE Directive (in particular Annex V, Part 2 and 3) provides combined targets for preparation for re-use and recycling per WEEE category. Member States and involved stakeholders (e.g. collective schemes for WEEE) can reach the targets by favouring recycling over preparation for re-use. As a consequence, the option of preparing for re-use might be neglected (Seyring et al., 2015).

The revised WEEE Directive gives the definition of re-use as the final objective of the preparation for re-use: “checking, cleaning or repairing operations, by which products or components of products that have become waste are prepared so that they can be re-used without any other pre-processing” (European Parliament, 2012).

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In many member states the definition has been interpreted differently and this will have an impact on tracking the flows. In some countries the volume of re-use can be measured as the volume of EEE coming out of the re-use centre (output) while others will pay greater attention to the origin of the EEE (input). A questionnaire was sent to representatives of Member States in order to gather their point of view on the definitions. Only two Member States out of fifteen did not see any issue with the definitions of “re-use” and “preparation for re-use”. Thus, as there is the overlap of the definition, most Member States report on quantities of EEE/WEEE re-used, without specifying if the products have actually become waste and were prepared for re-use (Seyring et al., 2015).

Eco-design & interoperability in EEE The Eco-design Directive (2009/125/EC) attempts to create a framework for defining requirements for the environmentally friendly design of energy consuming and energy related products placed on the EU market. Up until now, however, the focus on these solutions has been on improving energy efficiency rather than on material efficiency (e.g. Prakash et al., 2012). A study conducted by RREUSE (Reuse and Recycling Social Enterprises in the European Union), the network of the re-use centres in Europe, identified the following obstacles in the repair of fridges, dishwashers and washing machines (RREUSE, 2013).

Product components A lack of interoperability of key components across different brands and even within brands is making repair more difficult. When replacing an electronic board for example, it must be from the same make and model of the original appliance.

Additionally, there is increasing difficulty in disassembling products for repair. Increasing difficulty in separating individual components from the casing, or accessing key parts in the interior of appliances deters replacement and repair resulting in many appliances having no re-use potential. If it is not possible to open the outer case of a product without breaking it, the re-use potential of the products is completely lost. Spare parts The cost of spare parts often exceed production costs. For example, retail prices of timers for dishwashers are often much higher than production costs, but are critical components of the appliance. The length of time that spare parts are available to purchase also significantly impacts the potential repair of a given product. In addition, sometimes only a full set of spare parts can be purchased when only a single part is needed.

Information for repair and service Repair and service manuals used to be made easily available to re-use and repair centres. Nowadays, however, approved re-use and repair centres/networks often have to pay high prices for this information if they are not the direct, after-sales service providers of manufacturers. In addition, large household appliances are now often fully operated by electronic control boards. If there is a problem, the appliance can be hooked up to a laptop using relevant hardware and tested with fault diagnosis software. However, this software and hardware is often only available to the after-sales service providers of the manufacturers and not to all approved re-use and repair centres/networks. Lack of access to such tools and information significantly discourages repair. These findings are universal for most EEE, indicating a big discrepancy between the goals of the Eco- design Directive (2009/125/EC) and the industry of product design and manufacture. Reduction in the

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lifespan of EEE result in more and more products POM which comes into conflict with the EU goal on waste hierarchy of decreasing production.

Standardisation systems for management of WEEE in Europe Two non-profit organizations in Europe (CENELEC and WEEELABEX) provide voluntary standardised systems that aim to help facilitate trade between countries, create new markets, cut compliance costs and support the development of a Single European Market within the lines of EU regulations and directives concerning EEE Research and Development, and WEEE procedures, logistics and inspection practices. These organizations work together, under European Commission supervision, to unify their standards for maximum interoperability in EEE, increasing the usage life of equipment from producers, as well as increasing the volumes of EEE towards re-use and the efficiency of the WEEE system. The goal is to minimize the loss of valuable resources and to safeguard the protection of the environment.

The European Committee for Electrotechnical Standardization (CENELEC) was created in 1973 as a result of the merger of two European organizations, CENELCOM and CENEL. CENELEC is responsible for standardization in the electrotechnical engineering field and encourages technological development, ensuring interoperability of products, and guaranteeing the safety and health of consumers while providing environmental protection (CENELEC, 2016).

WEEELABEX is the acronym of a LIFE project “WEEE label of excellence” which took place from 2009 to 2012. The project was supported by the European WEEE Forum and had two objectives. To design a set of standards in relation to the collection, sorting, storage, transportation, preparation for re-use, treatment, processing and disposal of all kinds of WEEE. And, to set up a process of monitoring of WEEE processing companies through audits conducted by auditors trained by its Office. In 2014, the first 28 trained auditors where certified. To date, 73 auditors are qualified, covering all languages of the EU (WEEELABEX, 2016).

Legislation in Cyprus

The responsible authorities for the management of WEEE in Cyprus are the following:

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● The Ministry of Interior (MOI) is responsible for the overall management of domestic waste and the drafting of legislation and policy on waste. ● The Environment Service (ES) under the Ministry of Agriculture, Natural Resources and Environment (MANRE) is responsible for a variety of waste related matters such as recycling, packaging waste and hazardous waste. The ES is the responsible authority for the implementation of the WEEE Directive (Directive 2012/19/EU) in Cyprus and all waste management systems. ● Local authorities, such as Municipalities and Communities, under the Ministry of Interior are responsible for the collection, disposal and treatment of domestic waste and the operation of waste treatment facilities. ● The Customs Authorities under the Ministry of Transport, Communication and Works at Limassol port are responsible for inspecting incoming volumes of EEE and importers registration towards the recycling system.

As a full EU member state since 2004, Cyprus transposed both the WEEE Directive (2002/96/EC) and the RoHS Directive (2002/95/EC) into its national legislation. In 2015, the revised WEEE Directive (2012/19/EC) was transposed into national legislation (Table 1).

According to the EU Council Decision (2004/486/EC) of 26 April 2004, Cyprus, Malta and Poland, as new EU members, were granted an extension of 24 months for application of two Articles of the WEEE Directive (2002/96/EC). The first article concerned the separate collection of at least 4 kg per resident per year of household WEEE, with a deadline to achieve this target by 13 August 2005. This was applied up until the end of 2015. The second Article concerned the rate of increase per category per year, for recovery and re-use purposes, with a deadline of 31 December 2006 (Más, 2016).

Furthermore, since April 2005, WEEE producers and distributors in Cyprus are requested to register in the ‘National Registry for Producers and Distributors’ according to the WEEE Directive, stating the categories and quantities of products placed on the market in Cyprus. Small companies are obliged to report once a year and bigger companies every four months. In general, Cyprus has limited volumes of WEEE compared to other EU Member States (Table 5). Moreover, any person or establishment who is managing WEEE (collect, transfer, store, treat, deal, trade or export) needs to obtain a permit, according to the Waste Law (185(I)/2011), before starting its operation (Department of Environment, 2015).

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Table 5: Total volume of Waste Electrical and Electronic Equipment (WEEE) collected in the EU in 2013, by EEE category (Reprinted from Eurostat, 2016a)

Management of WEEE in Cyprus

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WEEE Electrocyclosis Cyprus Ltd From the end of 2006, existing recycling companies in Cyprus were interested in collecting and treating several WEEE streams such as small and large household appliances, computers, screens, and their peripherals and fluorescent lamps and batteries. The fact that Cyprus is an isolated island with a population less than a million habitats makes the presence of an integrated network of WEEE treatment facilities non-viable (Department of Environment, 2015).

In order to comply with the WEEE directive, in 2005 the Cyprus Chamber of Commerce (CCCI) founded a collective WEEE recycling system named ‘WEEE Electrocyclosis Cyprus Ltd’. In 2006, WEEE Electrocyclosis Cyprus Ltd, a non-profit organization, contracted Green Dot Cyprus to organize and operate the system and in 2007 an application for the licensing of the system was filed. Since 1st of June 2008 it is the only WEEE management system that is licensed and operates the management of both B2C (Business to Consumer) and B2B (Business to Business) of WEEE in Cyprus. The system includes the creation of two peripheral storing and sorting facilities for WEEE. Cyprus follows the concept of the Producer Responsibility, based on the ‘Polluter Pays Principle’.

Through the allocation of contracts to sister companies, ‘WEEE Electrocyclosis Cyprus Ltd’ fulfils all the necessary obligations of EU policy in terms of collecting and handling WEEE for further processing and re-use. This organization is also responsible for cataloguing producers and distributors of EEE and inspects their obligations towards the ‘Producer Pays Policy’. Until the date of official operation of the Collective System (December 2009) information concerning quantities put on the market was collected separately from producers and distributors. From 2010 onwards, companies that participate in the Collective System are obliged to declare their EEE volumes to the National WEEE Registry. By the end of 2015, 345 producers and distributors were registered, representing most of the Cypriot market.

Although Electrocyclosis is responsible partly for the collections and processing system, the responsible authority for all waste streams are the local authorities. Besides ‘WEEE Electrocyclosis Cyprus Ltd’, there is also an approved individual system, by the name, ‘TEKLIMA’, collecting only air- conditioning equipment put in the market by the company TEKLIMA (Department of Environment, 2015).

Collection infrastructure for all WEEE is present outside shops that have more than 400 m2 floor space and sell electrical and electronic equipment. These same shops are also responsible for the safety of the equipment to avoid looting by illegal collectors. This Figure 4: Plastic boxes for WEEE collection infrastructure is also present in green spaces in 8 out of 30 municipalities of Cyprus, and in central locations in urban areas.

The responsible company for collecting and transporting the equipment is KYKAN LTD (Figure 5). It transfers the equipment to the storing and processing facility in Geri, Nicosia, where all equipment is categorised by its size and type. The material is then weighed and sorted into six categories in relation to their future processing (Table 7). Collection, sorting and treatment of WEEE The frontline of collection of ‘WEEE Electrocyclosis Cyprus Ltd’ are three types of containers (Table 6, Figures 2 to 4). The plastic boxes receive 4% of the total volume of WEEE collected, and the skips 77% of the volume. Table 6. The containers used by WEEE Electrocyclosis Cyprus Ltd for the collection of WEEE

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Electrocyclosis containers Total number Items collected Locations

plastic boxes 120cm x 100cm 142 electrical and electronic outside shops and x 76cm (Figure 2) equipment services

blue plastic barrels (Figure 3) 67 fluorescence bulbs mainly in shops and services

skip containers-hook type 43 electrical and electronic scrap metal facilities (Figure 4) equipment

Figure 2: Plastic boxes for WEEE collection Figure 3: Blue Plastic barrel (Reprinted

(Reprinted from Electrocyclosis, 2016) from Electrocyclosis, 2016)

Figure 4: Skip containers hook (Reprinted from Electrocyclosis, 2016)

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Figure 5: KYKAN transportation Van for WEEE (Reprinted from Electrocyclosis, 2016) Table 7: Categories of WEEE in relation to their future processing.

WEEE categories Examples of WEEE

Small devices <50 cm ● Computing and printing equipment ● Sound equipment ● Monitors

Big devices >50 cm Mixers, Ovens, Microwaves, Coffeemakers etc.

Monitors and TV’s Computer, Household, Industrial

Fridges Dispensers, Household, Industrial, Display

Air conditioning systems Household, Industrial

Fluorescent bulbs Energy Saving, Tubes

Four companies are housed at the same location (Table 8). The facility also serves as a reception centre for WEEE from the public, government departments, companies and local authorities and receives 19% of the total volume of WEEE collected (Electrocyclosis, 2016).

The sorted WEEE is then either exported for treatment, or partly treated locally, and then exported (Table 9). It is loaded into containers and the highest anonymous bidder, an authorized WEEE dealer, is responsible for shipping the material for further processing towards European or OECD countries (Figure 6). This anonymity however, leaves Electrocyclosis in the dark with regards to the final destination of the e-waste leaving Cyprus, allowing for the possibility of the material ending up in the flow of illegal trade and processing.

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Table 8: Companies housed at storing and processing facility in Geri, Nicosia

Company Area of work

AE Metal Commodities Ltd Processing of fridges, by removing fluorinated greenhouse gases and shipping all equipment to a hi-tech facility in Europe for further processing.

Telli Enterprises Ltd Assessing EEE for re-use and then Sold in Cyprus and abroad

IESC Ltd Management of fluorescent and energy saving light bulbs

Afis LTD Collection and management of batteries.

Table 9: The fate of WEEE collected in Cyprus (Más, 2016)

Large household appliances (e.g. washing machines, Dismantled in Cyprus ovens, etc)

Ferrous metals retrieved from large household Sent to smelters in Greece appliances

Compressors and motors retrieved from large Depolluted in Cyprus and sent to third household appliances countries

Fluorescent bulbs (hazardous waste) Sent to EU countries, mainly England. No pre-treatment, only being crushed in a machine

IT equipment and CRT monitors Refurbished and sold in Cyprus and abroad

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Figure 6: Transboundary shipment of waste from Cyprus in 2013 (Reprinted from Eurostat, 2016c)

Collection volumes of WEEE In 2015, the Electrocyclosis network collected 1970 tons of WEEE (Table 10), corresponding to a 25% increase from 2014 and achieving 98,5% of the organization’s goal of 2000 tons for 2015. The highest increase was a 100% increase in the volume of collected electronic and IT equipment for re-use. This was collected predominantly from closing corporate companies affected by the economic crisis that started in 2010. The second largest increase was a 70% increase in the volume of collected refrigerators, as a result of many distributors transporting their old stock to the Electrocyclosis collection facilities.

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Table 10: Collected volume of WEEE in Cyprus in 2015 (Data taken from Electrocyclosis, 2016) EEE Categories tonnes 1. Large household appliances 176 2. Small household appliances 67 3. Information and telecommunications equipment 180 4. Lighting 30 5. Air Conditioning Systems 4 6. Refrigerators 832 7. CRT/TV sets 324 8. CRT/IT 93 9. From corporate pick-ups for Re-use 196 10. Other 68 Total collected Volume (tonnes) 1970

The largest volumes of WEEE are collected from metal scrap yards, and EEE producers and distributors who are members of the recycling system, with much lower contributions from mobile units and collection campaigns of Electrocyclosis Ltd., and municipalities and small communities (Figure 7). These percentages reflect the very low level of public participation towards the program, as well as the lack of information and incentives from local authorities, producers and distributors in order to increase the volumes of collected WEEE.

3% Municipalities 2% 23% Scheduled Collections Private Businesses 72% Scrap Yards

Figure 7: Incoming WEEE (Data collected from Electrocyclosis, 2016)

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Challenges in the management of WEEE

Not meeting collection targets The economic crisis which started in 2010 shrank the EEE market in Cyprus (Figure 8) and affected the revenues of the WEEE system, challenging the sustainability of Electrocyclosis Ltd. The company responded by increasing its volumes of collected WEEE to compensate for the reduced POM volumes. Another measure was to reduce its membership fees by 8%.

17347

14432 12456

9274 9285 9200 Quantities (tonnes) EEEQuantities

2010 2011 2012 2013 2014 2015 Year

Figure 8: POM of EEE in Cyprus for the period 2010-2015 (Data collected from Electrocyclosis, 2016)

One of the biggest problems the company is facing is the uncontrolled looting of containers from unauthorized collectors, a situation that has been aggravated by the global economic crisis. Illegal collection is one of the main factors preventing, not only Cyprus, but Member States in general, from reaching their collection targets, as it decreases the amount of WEEE that is reported (Magalini et al., 2014). Furthermore, equipment that need professional installation such as air-conditioning systems or ovens, and in general fitted appliances, (except refrigerators and TV’s) are collected in low volumes as it is more profitable to sell them as scrap metal or plastic.

Another major issue are scrap yards, many of which are not properly licensed, that do not process equipment correctly, making it almost impossible for Electrocyclosis Ltd. to further process equipment or reuse it. One of the most important steps in such processing - decontamination - is usually not undertaken, resulting in pollution. The Authority responsible for inspecting scrap yards are the State Environmental Services

According to Electrocyclosis (2016), despite its efforts to enforce the implementation of the legislation, EEE producers and distributors still violate the law and don’t contribute towards the system. In order to resolve this issue, Electrocyclosis Ltd. has been researching the possibility of establishing regular controls at Limassol port for EEE cargo. The measure was deemed a necessary one by the Cyprus Parliament in order to more effectively restrict unregistered companies importing EEE.

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In March 2015, the revised national regulation on WEEE (Table 1) granted the power to the port authorities to inspect if the companies are registered with the help of a centralized database system which is now in place and fully functioning (Electrocyclosis, 2016).

Moreover, another serious issue are the uncontrolled landfills that do not follow the requirements of the Landfill Directive (1999/31/EC) that regulates waste management of landfills in the European Union. There are approximately 113 unofficial and uncontrolled waste dump sites in Cyprus (BIO Intelligence Service, 2011). Although the EU issued a warning to Cyprus in 2012, it did not fully implement the Landfill Directive and was reprimanded again in 2015. Such a judgement imposes on Cyprus the obligation to swiftly implement a sufficient collection system for recycling of municipal waste and therefore for WEEE. Uncontrolled disposal of waste is one of the major reasons that Cyprus has not yet achieved the requirements of the WEEE Directive collection volumes, since accounted and unaccounted volumes end up in landfills.

In general, the relationship between the equipment POM compared to the level of WEEE collected, and the amount of material recovered and recycled are problematic even at the EU level. For instance, the quantities of recycled material represent a quarter of the total volume that is POM at best (Figure 9). Moreover, the volume of WEEE collected in Cyprus in 2013, compared to the volumes POM between 2010 and 2012, clearly indicates the need for a radically improved collection system on the island, in order to triple the collected volume and fulfil the 45% EU collection target (Figure 10).

Figure 13: Illegal disposal of mix waste including WEEE in Pedoulas (Drakontas Peak) a Natura 2000 site in 2011

Figure 9: (EEE) place on market and WEEE collected and treated, EU, 2007–13(Reprinted from Eurostat, 2016b)

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Figure 10: Total collection rate as a percentage of the average weight of EEE put on the market in the three preceding years 2010–12 (Reprinted from Eurostat, 2016b)

Enforcement, inspection practices and unaccounted streams have been identified as potential barriers to meeting collection targets, even at the EU level (Figure 11). Products are sometimes handled outside the waste framework, particularly in the case of professional equipment when collected and removed from the WEEE stream. These quantities need to be traced, or at least estimated, as they undermine collection performances. Limited awareness of improperly disposing small equipment, in particular, is still a challenge in many Member States, as these appliances are often discarded in the residual waste, instead of being collected separately (Magalini et al., 2014).

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Figure 11: Questionnaire on implementation difficulties among member states (Reprinted from Magalini et al., 2014)

According to different stakeholders, varying factors are perceived as being more important (Figure 12). For example, Government Institutions place higher importance on inadequate infrastructure for the collection of WEEE, and low levels of public awareness, compared to Business and Industry Associations that perceive the biggest difficulty as being the high rates of unaccounted collection that are translated as lost revenue (Magalini et al., 2014).

Figure 12: Evaluation of main difficulties by different stakeholders (Reprinted from Magalini et al., 2014)

Moreover, according to Magalini et al. (2014), the main reasons behind the unaccounted collection flows are the following (Figure 13):

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● ‘Cherry picking’ selective collection of profitable WEEE whole or component parts of WEEE that generate higher revenues. ● Lack of Reporting which threatens the effective functioning of the market ● Illegal collection violation of existing national (WEEE) or international legislation (Basel) and/or those that enable illegal activities under the cover of a legal business. ● Unaccounted treatment which, in many cases, may be a result of unaccounted collection and has an impact on the WEEE Directive reporting ● Illegal treatment is unaccounted by definition and is problematic in many ways as it is completely unregulated in terms of recovery and poses greater risks for the environment as well as for Member States to achieve their collection targets. ● Illegal Shipments (unaccounted WEEE exchange among countries) which in many cases towards non EFTA or OECD countries. These activities influence both collection and treatment targets which occur after recorded collection or unaccounted collection

Figure 13: High rate of selective picking and unaccounted collection (Reprinted from Magalini et al., 2014)

Limited inspection and enforcement capacities Limited inspection and enforcement capacities also constitute challenges at the EU level, and have been identified to be in need of improvement in order to achieve better compliance towards the collection targets of the WEEE Directive. The level of WEEE management is also essential for an efficient collection system, and stakeholders from many EU countries believe their management systems are adequate (Figure 14). In particular, three issues have been identified as meriting further attention (Magalini et al., 2014).

● Strong enforcement practices are needed to increase compliance, that is a crucial step in decreasing illegal or unaccounted activities. Enforcement practices may include mechanisms to encourage compliance by providing rewards or "incentives", or by outlining and administering punishments or "disincentives". ● Strong inspection capacities are necessary to enforce all practices necessary to comply with the WEEE Directive. Successful inspection practices face several difficulties. For instance, it is difficult to detect the leaks in collection, recycling and monitoring systems, as not all of these

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are illegal. The inspection system should ensure complete traceability of all the unaccounted WEEE streams. ● High level of management (execution) capacities. Member States should have enough execution capacity to be able to manage an efficient WEEE system.

Figure 14: Limited inspection and enforcement capacities (Reprinted from Magalini et al., 2014)

Implementation and Enforcement of Environmental Law (IMPEL) In order to address the need for stronger inspection and enforcement of environmental laws, a non- profit association, IMPEL (Implementation and Enforcement of Environmental Law), was established in 1992. IMPEL comprises the environmental authorities of the EU Member States, acceding and candidate countries of the European Union and EEA countries. The association is registered in Belgium and acts as an informal network of European regulators and authorities concerned with the implementation and enforcement of environmental law.

According to De Gier (2012), during 2008-2011 around 25% of all waste shipments within, or from, the EU were illegal, including violations of the export ban on hazardous waste to developing countries and waste for disposal to countries outside the EU and EFTA. To quote the former director of IMPEL “existing gaps in Member States inspection systems are one of the important drivers behind illegal waste trade. Exporters abuse these gaps by sending their waste through Member States with least controls (so-called "port hopping"), which undermines the enforcement of the Waste Shipment Regulation. Pressure also increases on EU ports if Member States do not sufficiently control waste at "up-stream facilities" (De Gier, 2012).

Countering WEEE illegal Trade (CWIT) To address these issues, a two-year project titled ‘Countering WEEE Illegal Trade’ (CWIT) took place from 2013 to 2015. The project was supported by the FP7 Framework Programme and brought together a group of professionals from the WEEE industry, enforcement agencies, international organisations, lawyers, academia and consultants specialised in supply chain security. The aim of the project was to provide a set of recommendations to the European Commission in order to assist stakeholders in countering the illegal trade of WEEE within and from Europe.

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The CWIT project found that in Europe, only 35% (3.3 million tons) of all the WEEE discarded in 2012 ended up in the officially reported amounts of collection and recycling systems. The other 65% (6.15 million tons) was either exported (1.5 million tons), recycled under non-compliant conditions in Europe (3.15 million tons), scavenged for valuable parts (750,000 tons), or simply disposed of in waste bins (750,000 tons). Therefore, the outputs of the project include a set of recommendations related to the European legal and policy framework, which take into account the objectives and constraints of all key government and business stakeholders. The project also provided a roadmap to assist in the implementation of all recommendations and ideas on future research and technologies that would contribute to the reduction of the illegal trade of WEEE.

Basel Action Network (BAN) Furthermore, another relevant non-profit organization, BAN (Basel Action Network), was established in 1997 with the mission to end the transportation of toxic waste from more developed to less developed countries. The organization focuses on the implementation of the Basel Convention (The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal).

During 2014 and 2015, BAN was involved in the e-Trash Transparency Project (Hopson and Puckett, 2016) which was the first large-scale e-waste flow study that observed actual e-waste movement from the United States (US) into the global marketplace. GPS trackers were planted into 205 old printers and monitors that were then delivered to US charities and recycling companies. It was found that 40% of the printers were not recycled in the US as expected by customers, but were instead exported to highly-polluting and unsafe operations in developing countries, mostly in Asia. More specifically, the exported tracked devices travelled to Hong Kong (37 devices), mainland China (11), Taiwan (5), Pakistan (4), Mexico (3), Thailand (2), Canada (2), and one each in the United Arab Emirates, Togo, Kenya, Cambodia, and the Dominican Republic. Most of the tracked devices were transported via ship and truck to 48 different sites in a semi-rural part of Hong Kong known as the New Territories. BAN officials travelled to this area and visited the precise locations where the trackers had ended up. They found massive volumes of LCD monitors, printers and other electronics being smashed daily and broken apart by hand in hidden junkyards, allowing the release of printer toners, and mercury phosphorus, being inhaled by workers who were both unprotected from, and unaware of, the hazards (Puckett et al., 2016).

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Future recommendations It is of paramount importance that POM is accurately measured. Therefore, a centralised system is needed at the EU level for measuring the volumes of EEE that are placed on each national market. As the responsibility to report these volumes is currently in the hands of the producers and distributors, such reports can be easily corrupted.

Of paramount importance are awareness raising campaigns to ensure that WEEE is disposed of properly by households and businesses. Municipalities in Cyprus need to increase their efforts in informing the public of the available collection system. Moreover, 8 out of 30 Municipalities and none of the 350 communities in Cyprus offer collection services of WEEE at their green public spaces. Additionally, producers and distributors need to provide incentives for consumers to increase collection volumes, especially in the category of small electronic devices.

It is possible to maximise the revenue generated from recycling by increasing the current research and development costs and creating the technologies to track and treat valuable materials that are difficult to access or recover. For example, the WEEE Forum, a not-for-profit association of 32 WEEE producer responsibility organisations (or ‘producer compliance schemes’) in Europe, has developed a database application by the name of WF-RepTool. The purpose of this tool is to help determine how WEEE is treated, in a transparent, traceable manner and to achieve consistent results. It allows the calculation of recycling and recovery rates in accordance with the requirements of the WeeeLabex standard and the WEEE Directive. With this software, the entire treatment chain of WEEE is documented, from collection and reuse preparation to dismantling/de-pollution, shredding and separation and final treatment technologies of recycling and recovery of materials and energy. The database can then generate accurate reports on the collected and treated WEEE that are essential for the purposes of the WEEE Directive required yearly volumes of Member States.

Production of secondary materials from WEEE receives a better price and will benefit the WEEE industry of Cyprus. Collecting and processing waste closest to the area it is being disposed, is a priority for the Waste Directive and prevents further CO2 emissions generated from shipping. For example, in an interview on the 20th of June 2016, Dr Giannos Vyrides, a researcher and Assistant Professor of Chemical Engineering, at the Cyprus University of Technology (TEPAK), states that it is both economically and environmentally sustainable to extract valuable metals from circuit boards through the process of bioleaching.

In addition, Gough (2016) mentions that a tonne of mobile phones, which is roughly equivalent to 6,000 handsets, contains about 130 kg of copper, more than 3 kg of silver, 340 grams of gold and 140 grams of palladium. The purpose of the article was to present the innovative research of Professor Veena Sahajwalla, a world class leading scientist in the sustainability of materials, from the Australian University of South Wales. Professor Sahajwalla is currently developing mobile portable micro- factories, roughly the size of a shipping container, which can be deployed at collection sites in suburbs, remote communities and throughout the developing world (Gough, 2016).

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Conclusion Reaching the new EU targets is challenging and even unfeasible for some Member States if the current pace is maintained. The main difficulties are linked to the high rates of selective and unaccounted collection, illegal practices, which are further amplified by the limited enforcement and monitoring capabilities of Member States. These interlinked difficulties are seriously damaging the Member States’ ability to achieve the target or to demonstrate the real amount of WEEE collected in their territories. As Electrocyclosis reported, large volumes need to be identified as well as their destinations, which are not collected by the system. The fact that it is up to the producers and distributors to report their POM volumes of EEE, poses a risk for calculating these volumes correctly.

Increased accuracy of unaccounted WEEE volumes, requires costly surveying and analysis, as well as proper reporting on the national level. For instance, while it is possible to have an estimation of the WEEE disposed of in waste bins by a population, it is harder to estimate the amount of awareness- raising required to change this habit of improper disposal, the costs of such activities and the results in terms of WEEE sorted and properly disposed of, that could be finally recovered (Seyring et al., 2015).

Cyprus has the potential to be in a far better situation because of its size and waste generated volumes, in comparison with other EU members that require vast amount of resources to regulate all aspects of the WEEE system, in order to comply with the new EU requirements, if they are not already doing so. The facilities of Electrocyclosis are in full compliance with the directives requirements and it is an excellent example of efficiency and transparency in the recycling industry, especially for other companies in the field to follow.

On the other hand, Cyprus is still far from the target of required volumes of both recycled and re-use WEEE streams. Cyprus needs to radically change its system since most of the volumes being lost are identified. Contribution from municipalities is almost non-existent and most of the small EEE equipment ends up in landfills which shows the extremely low level of public awareness and municipal responsibility. The fact that Cyprus has a big number of uncontrolled landfills and not yet explored the possibility of waste prevention programs is alarming, in terms of the environmental degradation and unregulated disposal of all waste streams. Landfilling vast amounts of counted and unaccounted WEEE limits the potential of achieving the goals of the WEEE directive.

The government has announced that all uncontrolled landfills will be closed by the 2017. This goal, if implemented, will impact waste management in Cyprus. Such action would be a very positive step towards the improvement of the collection of recyclable volumes in all waste streams, the creation of more green jobs, the decrease of lost valuable materials, the increase of public awareness, the endorsement by the government of recovery plants and more importantly the reduction of environmental pollution.

Finally, a stricter adherence to the EU waste pyramid by all Member States would be enough to sufficiently reduce waste by prevention and re-use. However, there are many problems regarding the European WEEE Directives in terms of the implementation, compliance and illegal practices amongst members. These problems could therefore be reduced if the European Commission would use Regulations instead of Directives (Van Acoleyen et al., 2016). Regulations don’t allow room for interpretation and are binding legislative acts and must be applied in their entirety across the EU by each individual Member.

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