The responsibility for the management of waste from electrical and electronic equipment: Myth and reality

The information disseminated in the media that waste recovery operators are about to increase the "product fee" on electrical and electronic equipment goods has prompted the public to expect and insist that the Ministry of Environment and Water (MOEW) intervene in this problem. However, MOEW is not the institution that can take a position on pricing measures, as license fees are determined by each individual recovery organization depending on the necessary costs for fulfilling their legally defined obligations.

The commercial relations between waste recovery organizations and their members are private law, as well as the financial arrangements between the individual parties. According to legal requirements, producers and entities placing products on the market, after the use of which mass-spread waste (MSW) is generated, bear the financial responsibility for the management of the waste from these products. The financial responsibility is fulfilled by paying a product fee to the Enterprise for Management of Environmental Protection Activities (EMEPA).

There is also an alternative - a legal possibility for these obligations to be fulfilled through collective systems, represented by a recovery organization (RO), or individually, in which case the requirement to pay a product fee to EMEPA is waived. The legislation does not in any way restrict the possibility of the obligated person to decide for themselves how to fulfill their commitments related to the care of the "future" waste.

The commitment of MOEW is to exercise maximum, systematic and effective control over the activity for the environmentally sound implementation of the national targets by the obligated persons, regardless of the price parameters of the activities. From 2012 until now, there has been an explosive growth in the volumes of electrical and electronic equipment placed on the market, which leads to a drastic increase in the collection and recycling targets.

The suggestions of a "huge jump" in product fee prices, and hence in electrical appliances, are unfounded. The amount of the product fee in Bulgarian legislation has not been changed since 2008 and is significantly lower compared to other European countries. The emerging proposal for the state to reduce the EMEPA tariffs for the product fee would be an unlawful attempt at a kind of state intervention and subsidy for the private business in the sector.

It is also inaccurate to suggest that the increase in the amount of these "eco-taxes" will be directly calculated into the final price for the consumer. This is an environmentally motivated surcharge on the product price, the purpose of which is to stimulate more environmentally friendly production and import, with less product weight, as well as the possibility for part of this price increase to be at the expense of corporate profits.

The main mission of MOEW is to fulfill the national targets for the collection and recovery of waste electrical and electronic equipment and thus limit the disposal of household appliances in unauthorized places. Whatever we produce and import and whatever the needs in the household and business, at the beginning and end of these processes and standards, the financial commitment to deal with the waste is invariable.