Japan Machinery Center for Trade and Investment
No.401 Kikai Shinko Building
5-8, Shibakoen 3-chome
Minato-ku, Tokyo 105-0011
JapanTelephone: 81-3-3431-9230
Facsimile: 81-3-3436-6455

5th June 2008
European Commission
DG Environment, Unit G4
BU5 – 5/121
Review of Directive 2002/96/EC(WEEE)
B-1049, Brussels, Belgium
Dear Madam / Sir,
Japan Machinery Center for Trade and Investment is a nonprofit organization
established in 1952 in accordance with the Export and Import Transaction Law. It
comprises about 300 major and medium-ranked companies engaged in exporting orinvesting in a broad range of machinery including manufacturers of electrical andelectronic equipment, trading firms and engineering companies.
Our committees handle environmental issues over products for trade and arestrongly concerned with environment-related regulations on products in Europe andother countries. From this standpoint, we would like to comment regarding theStakeholder Consultation on the Review of Directive 2002/96/EC.
We would like to express our thanks for the transparency of the Review of theWEEE Directive and are delighted to have this opportunity to submit our comments onthe Review.
If you have any questions, please feel free to contact our secretariat (Mr. Hideaki
Fukasawa, E-mail : fukasawa@jmcti.or.jp ).
Sincerely yours,

Takao Sato

Ryozo Sato

ChairmanCommittee on Trade and Environment

ChairmanCommittee on Environment Laws

Japan Machinery Center for Trade and Investment

JMCTI Comments
regarding the Stakeholder Consultation on the Review ofDirective 2002/96/EC
5th June, 2008

General Comments
We understand that the WEEE Directive needs to be reviewed to promote its efficient andeffective operation as stated in the objectives of the Consultation Document. We request thereview be conducted based on the most recent reality of circumstances in order to enableproducers also to respond in a practical manner.

1. Targets
The WEEE Directive requires producers including product manufacturers to recycle andrecover components and materials.
The levels of recycling and recovery of components and materials should be determined basedon the performance that each Member State has shown so far. Stakeholders should be allowed,
therefore, to access relevant data concerning reuse, recycling and recovery and to participate indiscussions for setting new targets in order to ensure agreement on final targets among manystakeholders.
We recognize that whole appliances are not being reused by manufacturers except in certain
cases for reasons of quality, safety standards, energy efficiency and others. We consider it
unnecessary, therefore, to set a new target of the reuse for them.

2. The Scope of the Directive
We are opposed to the option of extending the scope to spare parts and components. Spareparts and components are used inside equipment. Since equipment is covered by the directiveand measures are taken accordingly, we consider that the intended purpose of the directive is fullyserved. It is even considered meaningless to place WEEE symbol marks on those spare partsand components.
We are also opposed to the option of classifying equipment as being WEEE from privatehouseholds (B2C) or WEEE from users other than private households (B2B). Such categorization
will not work in practice in light of the fact that some products are in dual use as B2C and B2B.

Japan Machinery Center for Trade and Investment(JMCTI)
No.401 Kikai Shinko Building, 5-8, Shibakoen 3-chome, Minato-ku, Tokyo Japan 105-0011
Tel:+81-3-3431-9230, Fax:+81-3-3436-6455, WEB: http://www.jmcti.org/

13. The Operation of the Producer Responsibility Provisions
We are in favor of the option of interpreting and implementing the directive by placing thelegal basis for the provisions related to scope, definitions and product requirements in Article 95of the EC Treaty and that for the provisions related to targets and operation of treatment in Article
175, since we consider this reasonable.
As for the option of setting targets for reusability, recyclability and recoverability of equipment,on the other hand, we consider it important to clarify the concept of recyclability targets in thefirst place. Recyclability targets should be left to the judgment of manufacturers engaged indesigning products. As for reusability and recoverability targets, it is difficult not only to defineand implement, but also to verify them.

4. Treatment Requirements
We request that practically feasible and verifiable requirements be considered based on the way
in which collection schemes are implemented in the Member States and the current situations ofrecycling facilities.
Since actual treatment processes and levels are determined by the financial and technologicalcapabilities of individual recyclers, introducing and implementing unified treatment requirements
could hamper a fair competition among those recyclers.
The option of including the applications exempted under the RoHS Directive in Annex II.1 ofthe WEEE Directive should not be adopted, since practical implementation would become
extremely difficult.

Japan Machinery Center for Trade and Investment(JMCTI)
No.401 Kikai Shinko Building, 5-8, Shibakoen 3-chome, Minato-ku, Tokyo Japan 105-0011
Tel:+81-3-3431-9230, Fax:+81-3-3436-6455, WEB: http://www.jmcti.org/2