In September, the Parliament of the Republic of Lithuania adopted several amendments to existing laws which are expected-at least in theory-to impact the electronic waste sector in one way or another. After many years of deliberations, changes were made to the Waste Management Act, the Environmental Pollution Tax Act, the Environmental Protection Act, and the Administrative Offences Code. But will these changes truly bring the needed improvements to a market that undeniably requires them? Or are some of these amendments merely a way to soothe our conscience, to convince ourselves that we have “done something” because something simply had to be done?

L.Ivanauskas Director of the Electronics Distributors Association (EPA)

More electronics, more waste

Discussing environmental protection today is not easy. On the one hand, many people feel saturated with such discussions and have become resistant to them. On the other hand, geopolitical tensions and political theatrics now appear far more pressing. The ecological footprint created by warfare, or the demand for fossil resources used in advanced defence technologies, often fades into the background. Nevertheless, despite all the challenges, Europeans still want and can live more comfortably than before. The electronics market continues to grow: the variety of devices is increasing, and more of them are being sold and, unfortunately, thrown away.

These trends also drive the growing EU-mandated collection target for electronic waste. Based on product flows, this target currently stands at 65%. Unfortunately, in Lithuania the share of electronic waste that must be collected is not increasing as fast as the EU’s (and our national) requirements. Between 2020 and 2023, our annual rate fluctuated only between 32% and 39%.

Is Lithuania exceptionally unsuccessful in this respect? Thinking so would be wrong, just as it would be inappropriate to place too much blame on citizens or on the electronic waste collection infrastructure-which, as many experts confirm, is excellent. Moreover, very few EU member states can boast meaningful improvement in this sector. It is therefore natural that the EU’s concern about e-waste persists, and our lawmakers at least formally attempt to reflect this concern in national legislation.

Old problems, old and new solutions

We are well familiar with the history and motivations behind the legislative changes in Lithuania. As the largest association in the country organising electronic waste management and representing electronics manufacturers and distributors, we submitted proposals to government institutions, participated in discussions, spoke to the media, and raised essential questions. We conducted market research revealing electronic consumption levels, identified the public’s tendency to store unused or broken devices, and analysed the motivations that encourage responsible disposal.

We did not limit ourselves to words, routine processes, or traditional public awareness campaigns. Following European Commission recommendations, for the second year we have been implementing incentive-based electronic waste collection projects that offer tangible benefits to consumers: movie tickets, chances to win a trip, or the EPAcoin initiative. Residents earned EPAcoins for returning small electronic waste and could spend them when shopping in a central Vilnius mall. These are new measures supplementing the usual free-of-charge collection practices common across the EU-and they have delivered results we can be proud of.

Comparing the first half of 2024 and 2025, we see that in 2024 the EPA collection network gathered 969 tonnes of electronic waste, while this year the figure reached 1,130 tonnes-an increase of 161 tonnes. Unfortunately, the good news is overshadowed by the growing share of incomplete electronic devices in this stream. This change cannot be viewed positively.

Let me remind you why. First, incomplete devices indicate that someone dismantled them before disposal, removing valuable components, components that are in high demand on the market. Second, such incomplete items cannot be counted towards official electronic waste collection statistics. Although our association still pays for their recycling, no official recycling certificates are issued. This not only fails to move us closer to the required 65% target but also confirms the existence of a real illegal electronics market.

Stolen: property or trash?

I have often spoken about illegal electronic waste “recyclers”, although calling them recyclers is questionable. They do not process waste-they destroy it. In doing so, they also undermine the circular economy of electronics. Some of these incomplete devices end up in designated collection bins, but many without a doubt are thrown into mixed waste or packaging containers. We are glad that at least the waste entering our collection system does not end up in forests, but why should such incomplete devices not be counted towards the total collection volume if their processing is still paid for by electronics manufacturers and distributors?

Why does the state feel justified placing full responsibility on producers and distributors while doing nothing to curb the illegal electronics market? Should it not be the state’s duty to ensure the legality of the entire waste sector? After all, law enforcement institutions exist for this purpose and are funded by taxpayers. Effective collection and profitable recycling depend heavily on legality.

And what could be better than collecting waste responsibly so that it can become raw material for new products-especially when the market for mined metals is becoming increasingly constrained, and these materials are essential for household appliances, industrial equipment, and even defence technologies? Isn’t this very goal-recovering valuable materials and returning them to production, what all legitimate players in this sector should be striving for?

Incomplete items make up around 6% of all devices collected through our network, and this is significant. It also represents only part of the illegal market’s true scale. For years we have also raised the issue of electronic waste theft from collection containers. This activity is largely unregulated and often misunderstood. Who cares if someone steals trash? The question is not surprising; the answer is simple.

Illegal practices becoming routine: who is to blame?

In theory, all waste is still often referred to as “trash”, and electronic devices are no exception. They are thrown away as items that have become worthless to their owners. They are not assigned a monetary value, nor are the materials inside them-even though many are highly valuable. Thus, when we report a container with a broken lock to the police, typically only the damaged lock or container is assessed as the loss. Such cases are usually classified as minor damage, and investigations are not initiated. Only in rare cases, when the container itself is significantly damaged, are thieves penalized. But how can one accurately determine what was stolen and assess its value? Once again, no state law or institution helps manage this aspect of the illegal e-waste market.

This raises the question: do the recent legislative changes offer any real benefit in the near term? In principle, all amendments can be viewed as positive, but they are more cosmetic than solutions to deep-rooted issues. Among the more meaningful changes is the provision that producers and importers may switch their waste management organisation only once per year. This finally allows organisations that represent them to plan their activities more reliably and fulfil commitments.

However, the amendments introducing penalties for producers or importers who fail to meet government-mandated collection targets deserve criticism. Can fines truly have a positive effect on environmental outcomes? Or could they instead disrupt infrastructure and ultimately harm environmental objectives? It is no secret to the government what challenges the legal sector faces from illegal operators to the overall shortage of actual waste available for collection. Yet instead of addressing real problems and pursuing ecological and economic benefits for the electronic waste sector, the state shifts full responsibility onto producers and distributors. Perhaps this is done merely to soothe conscience? A rhetorical question, of course.