WEEELABEX Statement 2024: The revisions that redefined the audit

The 2024 revision of the WEEELABEX Statement was not a mere cosmetic update. It was a fundamental recalibration of how WEEE treatment operator compliance is assessed across Europe. For those who have already been through previous audits, many of the requirements will seem familiar in principle, but significantly different in their level of detail and rigour.

Context of the Revision: Why 2024?

Recent years have exposed a series of vulnerabilities in the previous system. Auditors reported difficulties in genuinely verifying the performance declared by treatment operators, and some certified facilities continued to operate below expected standards without this being flagged during audits. The 2024 revision came as a direct response to these gaps, while also aligning with the updated requirements of the EN 50625 series of standards.

New Audit Evaluation Criteria

Risk-Based Approach

The most significant conceptual change is the shift to a risk-based evaluation. Auditors no longer merely verify the existence of procedures; they assess whether treatment operators have identified the specific risks at each treatment stage and whether control measures are proportionate to those risks. Specifically, if a treatment operator processes significant quantities of cooling equipment, the auditor will devote disproportionately greater attention to the fluorinated gas extraction process than, for example, the manual disassembly of IT equipment.

Staff Competency Assessment

The 2024 Statement introduces a more structured competency assessment. It is no longer sufficient to present generic training certificates. The auditor now verifies whether each operator knows the specific hazardous substances contained in the equipment they treat, whether they can identify components requiring selective depollution, and whether they understand the consequences of omitting a depollution step.

Strengthened Documentation Requirements

Documentation has always been a pillar of WEEELABEX, but the 2024 revision raises the bar significantly:

• Depollution register: must contain records of each depollution operation performed, not just aggregate quantities. Each treated batch must be linked to the depollution operations carried out.
• Output fraction records: each fraction resulting from treatment must be documented with the quantity, waste code (according to the European Waste List), and actual destination, not just the contractual one.
• Process monitoring: evidence of continuous monitoring of critical process parameters is now required (for example, pressure in gas extraction systems, particle size after shredding).
• Internal non-conformity records: treatment operators must demonstrate that they have a functioning system for identifying and correcting deviations, not merely a formal procedure.

Output Fraction Verification: The New Focal Point

This is arguably the area with the greatest practical impact. Until 2024, auditors primarily verified whether output fractions were documented. Now, the verification goes much deeper:

• The auditor may request evidence from fraction recipients – reception confirmations, composition analyses, or recycling certificates – to validate that the declared fractions actually reached the stated destination.
• Mass balance coherence is verified: the total quantity of output fractions, including documented losses, must correspond with the input quantity. Accepted tolerances are now tighter (below 5% for most categories).
• Special attention is given to mixed fractions – treatment operators who declare fractions with generic codes (e.g., "mixed metals") without a clear technical justification will be penalised.

Depollution Under the Microscope: How Auditors Evaluate

Depollution has always been the central WEEELABEX requirement, but the method of evaluation has changed. Auditors now apply a three-step approach:

• Documentary verification: updated depollution procedures, lists of hazardous substances per equipment category, work instructions at each workstation.
• Direct observation: the auditor observes the depollution process in real time, verifying whether operators follow the instructions and correctly identify hazardous components.
• Cross-verification: the quantities of hazardous substances extracted (PCB capacitors, batteries, mercury from lamps) are compared with the quantities of equipment treated, to assess whether the proportions are plausible.

A treatment operator who declares having treated 500 flat-screen TVs but extracted zero mercury lamps will be immediately flagged. Proportions matter, and auditors now have statistical benchmarks for each category.

Changes in Sampling Methodology

The sampling methodology according to EN 50625-3-1 (TS) has been better integrated into the WEEELABEX audit process. Auditors now verify not only whether treatment operators perform sampling, but whether:

• The sampling frequency is adequate for the treated volume and the variability of the input stream
• The sample size meets the minimum statistical requirements of the technical specification
• Sampling results are effectively used for process adjustments, not merely archived
• There is a clear action procedure when sampling reveals non-conformities

What This Means for Recyclers in Romania

Romania has a relatively small number of WEEELABEX-certified treatment operators, but the pressure for certification is constantly growing from PROs and regulators. The 2024 revisions bring several specific challenges for the local market:

• Investment in record-keeping systems: paper registers or simple spreadsheets are no longer sufficient. Digital systems that ensure complete traceability are required.
• Continuous training: a single annual training session is no longer acceptable. Staff must demonstrate updated and specific competencies.
• Documented relationships with fraction recipients:framework contracts are no longer sufficient. Concrete evidence of each delivery and confirmation of the final destination is required.

The good news is that treatment operators preparing now for certification will implement the updated requirements directly, without having to go through the painful transition process from the old requirements. Those already certified have the current audit cycle to align with the new standards.