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					          Questionnaire on impacts of RoHS/WEEE Directives
                   ARCADIS ECOLAS/RPA study
            for the European Commission, DG Enterprise



Coverage
Could you please indicate the products covered under your organisation and the numbers of
companies that are a member of your organisation. [Please place an X in the relevant box]

                                                       Covered?          Number of member
                   Product
                                                                            companies
 Refrigerators
 PC and laptop, including spare parts
 Printers and copiers
 Cellphones
 Television set
 Clocks and watches
 Fluorescent lamps (straight and compact)
 Lawn mowers + gardening equipment
 Video games and handheld video games
 Dispensers for hot and cold beverages
 Other: please specify


Could you please indicate the percentage of companies represented by your organisation by
company size?

                                                       %                %                 %
 Number of employees:                         <50              <250              >250
 Annual turnover:                           ≤€10m             ≤€50m             >€50m

What is the total market share (by product category) covered by the members of your
association?

                                                    % of total market volume   Market Value (€)
                   Product
                                                           by product
 Refrigerators
 PC and laptop, including spare parts
 Printers and copiers
 Cellphones
 Television set
 Clocks and watches
 Fluorescent lamps (straight and compact)
 Lawn mowers + gardening equipment
 Video games and handheld video games
 Dispensers for hot and cold beverages
 Other: please specify



                                                    Page 1
1. Impact of the RoHS Directive
Please list the main RoHS activities that are causing administrative burden according to your
opinion:




Which of these activities are not fundamental in your opinion?




In your experience, which products subject to the RoHS Directive are at the limit regarding
costs and benefits?




Overall, do you believe that the burden of compliance is being shared equitably among
producers? [Please place an X in the relevant box]

           Yes                                             No

If no, please explain




How much do you agree with the following statement:

   SME’s have been affected to a greater degree by compliance with the RoHS legislation
   than their larger competitors [Please place an X in the relevant box]

 Strongly Agree         Agree           Neutral            Disagree         Strongly Disagree



Could you please provide the reasons behind your answer:




                                           Page 2
According to your opinion, does the RoHS Directive have a significant impact on
competition in the EEE market? [Please place an X in the relevant box]

           Yes                                               No

If yes, please explain:




In what way does the implementation of the RoHS Directive result in new needs for RoHS
training or information measures in your organisation? [Please place an X in the relevant box]

                                          Frequency of RoHS training and information measures
                                         Once   Monthly Annually        Other frequency, please
                                                                                specify
General information campaign
Communication with companies
Informative staff meetings
Training workshops
Publication of leaflets
Placing of information on the intranet
Placing of information on the internet
Other, please specify:



How much time is dedicated to these training or information measures?

                                                  # Full Time Equivalents
                                                  OR
                                                  % of a Full Time Equivalent

Were new jobs created for these training or information measures? [Please place an X in the
relevant box]

                                                       Yes        No
Permanent
Temporary
Contracting of freelancers/consultants
Other, please specify:


If yes, please indicate which particular jobs in which areas are created:




                                              Page 3
2. Impact of the WEEE Directive
Information for Manufacturers and Distributors on the WEEE Directive

What, in your view and for the sector your members represent, is the percentage of producers
aware of the WEEE Directive and their responsibilities in the disposal phase of electronic
items?

 Product                                               % of producers aware of

 Refrigerators
 PC and laptop, including spare parts
 Printers and copiers
 Cellphones
 Television set
 Clocks and watches
 Fluorescent lamps (straight and compact)
 Lawn mowers + gardening equipment
 Video games and handheld video games
 Dispensers for hot and cold beverages

If for any of the above product categories you consider that the percentage of producers being
unaware of the WEEE requirements is high, please explain why you think this is.

 Product:


What information do producers have access to and/or utilise which explain WEEE
requirements for the design and disposal of electronic products?

 Product:


Do you provide this information?

            Yes                                           No

If Yes, explain how.




                                            Page 5
Compliance

As a producer representative organisation, do you feel that producers of EEE products are
meeting obligations about the materials used and safe disposal requirements under the WEEE
Directive?

            Yes                                           No

If you answered „No‟, please could you provide reasons for your answer below.




Based on 2003 data, the European Commission‟s Institute for Prospective Technological
Studies estimated free riders represented “between 10-20% by volume of product placed on
the market (although the percentage of non compliant firms is often higher, the smaller ones
falling through the net)” across Europe. What would be your best estimate currently of the %
of free riders by volume of product placed on the market in your country and how might this
number be reduced? [Please place an X in the relevant boxes]

 Product                                    0 – 5%   5 – 10%   10 – 15%   15 – 20%   20 – 30%
 Refrigerators
 PC and laptop, including spare parts
 Printers and copiers
 Cellphones
 Television set
 Clocks and watches
 Fluorescent lamps (straight and compact)
 Lawn mowers + gardening equipment
 Video games and handheld video games
 Dispensers for hot and cold beverages

How might this number be reduced?




                                            Page 6
Innovation and Knowledge Transfer

What do you consider to be the most important drivers of innovation (in the area of product
design for waste reduction and/or recycling) for your sector and products? [Please score 1 for
most important, 2 for the next most important and so on]

 Innovation Driver                                                               Rank
 Company‟s own environmental policy
 WEEE Directive
 RoHS Directive
 Other EU legislation [Please specify]:
 In-country or National legislation
 Consumer demand/preferences
 Legislation from other countries outside EU
 Reduction of costs of dealing with waste/recycling
 Other 1 [Please specify]:
 Other 2 [Please specify]:

Do you think that producers understand that one of the objectives of the WEEE Directive is
to achieve benefits in terms of innovations in the design of products which lead to either an
overall reduction in waste or an improvement in the recyclability of products.

            Yes                                                  No

If you answer „No‟, please could you explain the reason why you think this is so below.




How much do you agree with the following statement [Please place an X in the relevant box]:

    The systems of producer responsibility being implemented are affecting producers’
    ability to improve the design of their products in terms of the environmental friendliness
    of the materials and technologies being used and the ability for products at the end of
    their life to be recycled or disposed of appropriately.

     Strongly Agree              Agree                 Neutral        Disagree   Strongly Disagree



Could you please provide the reasons behind your answer below.




                                                      Page 7
At which stage in the EEE products life are WEEE requirements affecting manufacturing
activities? Please rank (1 is the „most affected‟; 3 is the „least affected‟). If you think that a
stage of not being affected by the WEEE Directive, add „No‟.

                   Stage of the Life-Cycle                        Affected by the WEEE    Rank, if
                                                                        Directive?       applicable
 1) Product design stage (reduction of toxic materials, designs
 which favour ease of recycling requirements)
 2) During production process (including possibilities to re-
 use, refurbish and/or repair equipment that would have been
 disposed of before implementation of the Directive)
 3) At distribution of products and arrangements for disposal
 of obsolete or broken items (ease of disposal, joining take-
 back schemes, etc.)

Please, could you provide examples on the above, if possible.




Do you have available any estimates of the overall costs in R&D and re-design of production
systems as a result of innovations which are motivated by the WEEE Directive from your
members?

             Yes                                                    No

If you answer Yes, please provide details below.

 Innovation                                  Estimate of Overall Cost in R&D and re-design of
                                                          production systems/€




Overall, do you think that the WEEE Directive has encouraged your members to exchange
information on product design and/or strengthened knowledge transfer.

             Yes                                                    No

If you answered Yes, could you please provide examples below.




                                                    Page 8
Impacts on Competitiveness

After introducing innovations to either reduce the level of waste in EEE products or to
improve their recyclability, have there been difficulties (other than costs) in the functioning
of the sector? e.g. availability of suppliers of component parts or materials? Exclusive
agreements?

             Yes                                            No

If your answer is „Yes‟, please provide any relevant details below.




Overall, do you believe that the burden of compliance is being shared equitably among
producers?

             Yes                                            No

   If you answer No, could you provide the reasons behind your answer below.




How much do you agree with the following statement: [Please place an X in the relevant box]

   SME’s have been affected to a greater degree by compliance with the legislation than
   their larger competitors

      Strongly Agree         Agree             Neutral           Disagree       Strongly Disagree



   Could you please provide the reasons behind your answer below.




How much do you agree with the following statement: [Please place an X in the relevant box]

   The systems of producer responsibility implemented has resulted in some waste
   management companies dominating the market

      Strongly Agree         Agree             Neutral           Disagree       Strongly Disagree




                                             Page 9
    Could you please provide the reasons behind your answer below.




Impacts on Trade

Are you aware of any difficulties experienced by your members in registering with Producer
Responsibility schemes in other countries? [Please place an X in the relevant box and if your
answer is ‘Yes’, please could you provide examples in the space provided]

           Yes                                                   No
     Examples:


     Have these difficulties been resolved? How?




Next Steps

Would you be willing to provide more detailed information, if needed, on the impacts of the
WEEE Directive with respect to innovation and competition for your trade association‟s
members?

              Yes                                         No
     If „Yes‟, please indicate what topics you would be willing to cover or think should be
     covered.



Finally, if you feel that we have missed anything important, or would like to comment on any
of the issues raised by this questionnaire, please provide details in the box below (and
continue on a separate sheet if necessary).




Thank you very much indeed for taking the time to complete this questionnaire. Your
responses will be kept confidential and utilised alongside others (and not attributable to your
individual organisation) solely for the purposes of the review of the Directives.


                                               Page 10

				
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