Some challenging Danish EPR experiences with electrical and electronic products .....SV: [SCORAI] Fwd: WG: International Law & EPR

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Michael Søgaard Jørgensen

May 27, 2023, 8:21:15 AM5/27/23

Dear Pascal


It is an interesting and important that the TES Academy initiates analyses of the role of EPR in transitions towards a more circular economy.


Maybe some of the Danish experiences can be interesting in the TES Academy process, because these experiences challenge the environmental potentials of EPR.

As a researcher within circular economy and sustainable transitions, I would say that we have bad experiences with EPR enabling any kind of preventive environmental efforts in relation to electrical and electronic products. I would be happy to contribute with a critical perspective based on these experiences.


In Denmark, EPR is a national implementation of EU regulation, and part of our problems in Denmark might be explained by a implementation of the EU WEEE regulation primarily focused on waste management. The Danish implementation includes no preventive efforts.


WEEE EPR without preventive impact

Most retailers and manufacturers within electrical and electronic products in Denmark are members of a collective scheme, which organizes the collection of the WEEE. The members pay a weight based fee, mainly to the collective scheme and a small part to the Danish Producer Responsibility Agency and are responsible for organising collection of a waste amount equalizing the weight of the products they have introduced on the market.


The collection and handling of WEEE has in the biggest collective scheme been organized through tenders and it got to a situation some years ago where the bids become so cheap that some WEEE-companies went bankrupt and left WEEE on their premises. A Danish municipality is still struggling with some of this old waste and its pollution of soil.


It is not the products a company introduced to the market they are responsible for handling. This implies that there is no possibilities for preventive learning from how the products wear through use.


The recent EU request for WEEE fee modulation

The EU Commission asked some years ago the member states to revise their WEEE EPR schemes in order to make the schemes more preventive by introducing modulated waste fees based on differences in the waste handling costs. This implies that the modulation of the waste fees most probably will be limited and give no significant economic incentive for manufacturers and importers to introduce environmentally better products. Furthermore, the EU has not yet managed to agree on criteria for the modulation.


Danish modulation of WEEE fees

The Danish EPA chose in the meantime to propose a Danish modulation of the WEEE waste fees, while awaiting the EU proposal.


The Danish modulation is innovative in the sense that it offers a 20% discount of the WEEE waste fee if a manufacturer or importer offers a 2-year product guarantee on the top of the present 2-year warranty period. However, this 20% discount implies no economic incentive for manufacturers or importers because this reduction equalizes a discount of around 2 Euro on a laptop!


According to the marketing law, the 2-year extra product guarantee should be visible on the product. Ideally, this might be make consumers choose products where the manufacturer or importer assumes a longer product lifetime is possible and thereby the amount of WEEE could be reduced. However, we don’t know whether any manufacturers or importers will apply this opportunity.


I am happy to discuss these Danish experiences as part of the TES Academy process.




Michael Søgaard Jørgensen

Associate Professor, PhD


Department of Planning

Aalborg University

A.C. Meyers Vænge 15

2450 Copenhagen SV



Tel. +45 9940 2967 /Mobile: +45 2125 6815

Skype: michael.soegaard.joergensen

Web page: 




Fra: <> På vegne af Pascal Frank
Sendt: 25. maj 2023 12:46
Emne: [SCORAI] Fwd: WG: International Law & EPR


Dear SCORAI community,

 My name is Pascal Frank. I work at the recently established “International Academy Transformation for Environment and Sustainability (TES Academy)” at the German Environment Agency. The Academy aims at providing a joint learning and action environment by bringing together experts for all relevant fields on a topic with external partners from science, administration, industry and civil society.  We aim to address institutions and individuals with the potential to implement lessons learned in their institutions and via new collaborations in the specific policy context of a topic.

We are currently setting up a transformation process on “Promoting Extended Producer Responsibility (EPR) in international law for a sustainability transformation towards a circular economy” where we aim at reflecting on the EPR approach as one tool for achieving transformation towards a circular economy. The process will start with a workshop from 27th to 29th of June in Dessau-Rosslau, Germany at the premises of the German Environment Agency. We have already won a series of participants from different professional, organizational, and international backgrounds.  For details on the workshop and the overall process, please take a look at the attached concept note. The workshop from 27th to 29th of June will only be the start of a process planned for about 9 months.

We are currently trying to integrate more critical and holistic perspectives on the topic, reflecting EPR within the larger framework of over-consumption, just transitions, material footprints etc. I thought this community might be the right spot to connect to experts in these areas who might be interested in joining our event (or even the entire process). Travel expenses will be reimbursed.

I'm happy to answer and discuss any further questions. Please do not hesitate to get in touch,

Thank you for your time in considering this invitation,

With kind regards,



Dr. Pascal Frank


Presidential offices / Präsidialbereich

International Academy Transformation for Environment and Sustainability (TES Academy)



Wörlitzer Platz 1

06844 Dessau-Roßlau


Tel: +49 (0)340 2103-2981

Fax: +49 (0)340 2104-2396


Von: Patrick Schroeder <>
Gesendet: Donnerstag, 18. Mai 2023 17:34
Cc: Frank, Pascal <>; Neßhöver Dr., Carsten <>
Betreff: International Law & EPR


Dear Garam,


Hope this email finds you well. Let me introduce you to Pascal and Carsten from the German Environment Agency who are organizing a workshop and process on “Promoting Extended Producer Responsibility (EPR) in

international law for a sustainability transformation towards a circular economy”. Attached is the concept note with more information.


I thought ITU’s experience on the international dimensions of e-waste management and related EPR legislation could be useful here.


I let Pascal and Carsten follow up with more details.


Best wishes




Dr Patrick Schröder
Senior Research Fellow
Environment and Society Programme

The Royal Institute of International Affairs

Chatham House
10 St James's Square
London SW1Y 4LE



Independent thinking since 1920


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