The Government's efforts to implement the two Directives have already attracted criticism from the Better Regulation Task Force (ENDS Report 343, pp 42-43 ) and the House of Lords European Union Committee (ENDS Report 347, pp 36-37 ).
At the end of last year, the Environment Committee heard complaints about Whitehall's performance from industry, as well as forecasts of inadequate capacity for dismantling and processing scrap cars and for accepting WEEE at civic amenity sites. There was also concern that implementation of the ELVs Directive could aggravate the problem of abandoned cars (ENDS Reports 346, pp 37-38 , and 347, pp 35-36 ).
The Committee's report is more a skim across the surface than an in-depth examination of Whitehall's strategy for making the two Directives work on the ground. Nevertheless, it still makes some telling observations.
The Committee believes that the Government has not repeated the mistakes that led to the fridge fiasco two years ago - "at least not on anything like the same scale". But it still feels that Whitehall has been neither efficient nor effective in transposing the Directives - and expects the problem of abandoned cars to get worse because of the way that the ELV Directive is being implemented.
One of the Committee's strongest concerns is over the Government's intention to use the "own marque" system for recovering ELVs after 2007. Before then, the last owners of vehicles will be responsible for their disposal. From 2007, manufacturers will contract directly with dismantlers to deal with their waste vehicles.
The alternative advocated by the British Metals Recycling Association is that dismantlers should be paid indirectly via a central fund, enabling them to deal with any make of vehicle.
The BRMA argues that the own marque approach will force consolidation in the sector because vehicle manufacturers will favour larger dismantling businesses, leaving some of the population more remote from recycling facilities as smaller sites shut down. Dismantlers will also be more reluctant to invest in improved facilities when their work could be taken away overnight.
Meanwhile, local authorities fear that dealing with abandoned cars will be more complicated under an own marque approach, since they will not be able to use a single contractor to deal with all vehicles.
The Committee sides with the critics. "The evidence we have received," it says, "makes us seriously question the 'own marque' approach," and it urges the Government to "re-examine" its policy.
Another issue on which the Committee wants the Government to think again is its plan to exclude printer cartridges from the rules on WEEE recovery.
Cartridge remanufacturing businesses have been warning that they are under severe threat because printer manufacturers are increasingly using technical devices to make remanufacturing impossible, and want the products covered by a recovery obligation (ENDS Report 342, p 33 ).
Echoing industry demands during the inquiry, the report recommends that the Government should issue guidance on the new regimes as soon as possible so as to end the uncertainty which has discouraged investment in ELV and WEEE recovery facilities.
In similar vein, the Committee wants the Government to set out precisely what extra resources are being made available to local authorities to deal with abandoned cars, and to the Environment Agency for the coming surge in licensing and enforcement work.
The report makes anodyne recommendations about the role of civic amenity sites in WEEE collections.
It recommends that the current network be expanded and existing sites developed to accept WEEE, assisted by streamlined waste management licensing and planning procedures.
The Committee was "particularly concerned" to hear industry complaints that the Environment Department lacks the skills and capacity to deal with complex EU legislation, echoing sentiments aired at a previous waste inquiry.
Environment Minister Elliot Morley claimed that the problem had been fixed, but the Committee wants DEFRA to review the workload on its officials, and especially its lawyers.
It also advocates two-way secondments between DEFRA and the waste sector, and the early involvement of the Environment Agency and other stakeholders in negotiations on EU laws.
Another business complaint was that the division of responsibilities for implementing the Directives between DEFRA and the Department of Trade and Industry had led to confusion and, according to retailers, "often misleading guidance".
The Committee believes the problem should be solved by having a lead Department for each EU Directive and a project management approach to implementation.