New e-waste model: Opportunity to improve?
In July 2023, the Department of Climate Change, Energy and the Environment and Water (DCCEEW) released an e-waste product stewardship discussion paper for public review.
The paper proposes major changes to the policies and regulations that govern e-waste recycling in Australia – particularly the National Television and Computer Recycling Scheme (NTCRS).
The proposed changes will increase the categories of electrical products (e-products) that must be recycled and introduce a single scheme administrator that will oversee the e-waste recycling system. You can read more about what’s changing here.
Positive direction for Australia’s e-waste system
Australia and New Zealand Recycling Platform (ANZRP) supports the government’s proposed changes as a positive step towards a better e-stewardship system. It is a strong sign from government that they are serious about tackling thee-waste issue.
As a not-for-profit organisation that has been a leading e-stewardship service provider for over 12 years, ANZRP has been a strong advocate for improvements to the current model of e-stewardship in Australia and therefore are pleased to see many more categories of e-waste being included in the proposed changes as this will significantly increase the amount of e-waste being recycled.
A greater focus on public awareness and education is also welcomed. Public understanding of the e-waste problem will help ensure that e-products are disposed of properly. It will also help encourage the purchase of more sustainable e-products, providing important market signals to manufacturers and designers.
While we applaud the ambition displayed in the discussion paper, there are still many improvements that government can make before finalising scheme design.
Three areas requiring attention in the government’s proposed new model
ANZRP has been responsible for recycling over 220,000 tonnes of e-waste over a 12 year period of operation. Through this work, ANZRP have helped develop e-waste recycling systems and infrastructure in Australia.
There has been over a decade of learning from industry, government and co-regulatory arrangements, which have become part of the current e-waste model. While we strongly advocate the need for further improvements, it is crucial that past learnings are not ignored.
There are three areas that the government must address in the proposed scheme design.
1 Brand agency is necessary to turn companies from compliers to true stewards of e-products.
Currently, brands are given agency to choose how their e-waste liability is discharged under the NTCRS. Producers and importers of liable products are able to pick between competing co-regulatory arrangements and form a direct relationship to the process of recycling.
This agency gives brands a sense of ownership and responsibility and provides an avenue for them to go above and beyond minimum standards and differentiate themselves.
The proposed changes would see brands simply pay a fixed fee to a scheme administrator to discharge their liability. Tackling e-waste becomes a matter of paying a fee, rather than a meaningful business choice.
By stripping brands of the agency of choosing how their waste is recycled, they are also stripped of the opportunity to be true stewards of their e-products and a continuous improvement focus is lost.
ANZRP proposes that any model the government puts forward incorporates a direct relationship with between brands and network operators (see diagram below).
2. Standards must set a higher bar and provide incentives to go above and beyond; they must also be adequately enforced.
ANZRP has been an advocate for stronger standards in e-waste recycling for many years. The bar is currently set very low, allowing for poor practices across the industry. Additionally, standards are not enforced with enough frequency, meaning that poor practices can continue for a long time, undermining the positive outcomes achieved by others.
The proposed government changes do not make mention of standards and the need to raise and enforce them, which is a key area of omission.
To improve the current system, this is an area that should be a priority. At a minimum, government should set standards of ISO 9001, ISO 45001, ISO 14001 and AS5377 to assure quality environmental outcomes are achieved.
Additionally, these standards must be enforced by the scheme administrator with appropriate frequency to ensure that poor practices cannot go on for too long. Poor practices not only have negative environmental outcomes but also reduce public trust in recycling which impacts the ability to encourage better consumer recycling practices.
There must also be some incentive for companies to go above and beyond the minimum standards and to move beyond simple compliance. The proposed model by government implies that this should be handled by voluntary product stewardship schemes. ANZRP is concerned that relying solely on voluntary schemes to deliver improved standards of recycling will not deliver the required outcomes.
Of concern is that this type of model could lead to a large proliferation of voluntary schemes that could create many different standards that are not harmonised. This would not only add costs for industry but would add costs for government who would need to oversee these different schemes.
3. Remote communities must be treated differently, and there must be local involvement.
ANZRP services some of the most remote communities in Central Australia, the Northern Territory and northern Western Australia. Our experience of providing e-stewardship services to remote communities has shown that it requires a very different approach.
The current model proposed by government does not make a clear statement about how remote communities will be serviced with e-waste recycling services. Volumes from remote communities are extremely low, making recycling far from cost-effective, yet providing access to these communities is critical.
Local involvement and partnerships have been a key part of delivering services and promoting e-waste recycling in these remote communities.
Local councils and community groups also play a large role in e-waste recycling in non-remote areas yet are not featured in the proposed changes. It is not clear how the single scheme administrator will manage these different local groups.
It is critical for any proposed change to articulate the role of local community and government in e-stewardship, as both are key players in the e-waste system.
A pathway to better e-stewardship in Australia
The past 12 years have taught us many lessons about e-waste recycling. It is important for any new model to understand these learnings and build on the foundations of the current system.
By building on what works well now, ANZRP is confident that Australia will be on a pathway to better e-stewardship which supports a rapid transition to a circular economy.
