Tuesday, August 04, 2009

Proposals for recycling old TVs and Computers

The Australian and New Zealand governments are considering how to recycle old televisions and computers. The Environment Protection and Heritage Council of has released a Consultation Regulatory Impact Statement: Televisions and Computers" (170 pages, 1.23 Mbyts of PDF, July 2009). Forums were held and written comments are invited by 13 August 2009. Of the nine options in the report, my preference is for option 1 (joint responsibility for collection) followed by option 2 (major computer brands responsible for their own products).

Available are:
  1. Consultation Regulatory Impact Statement: Televisions and Computers - July 2009Code of Practice for Managing End-of-Life Televisions - July 2009
  2. Willingness to pay for e-waste recycling - July 2009
  3. Submission template - Television and Computer Product Stewardship Consultation Package
  4. Statement on End of Life Televisions and Computers - Nov 2008
Executive summary

This document is a consultation regulatory impact statement for end of life televisions and computers put out by the Environment Protection and Heritage Council.

Introduction

Electrical and electronic products, in particular televisions and computers, constitute a significant element of Australia's material consumption, domestic environmental impact and waste to landfill. In 2007/08, 31.7 million new televisions, computers and computer products were sold in Australia, which is equivalent to 1.5 new units per person every year. In the same year 16.8 million units reached their end of life, which is close to one unit per Australian. Of these units, it is estimated that 88% were sent to landfill, with only 9% being recycled. Over the next 20 years, a significant volume of televisions, computers and computer products for disposal/recycling is expected to be generated, with expectations that the end of life volume will more than double. Waste volumes are increasing with shorter life spans of product and increasing ownership of electrical products, with the number of televisions, computers and computer products reaching their end of life expected to grow to 44.0 million by 2027/28.

Internationally, programs are being developed or implemented to reduce the environmental impact of electrical and electronic products. The European Union and Japan have already implemented legislation requiring the recovery and recycling of televisions and computers whilst other Organisation for Economic Co-operation and Development (OECD) countries are in the process of introducing a range of mechanisms to address this issue.

Australia’s consideration of an approach for managing e-waste has been ongoing since the 1990s when national electrical and electronic waste management was put forward as an emerging priority by industry to the Australian and New Zealand Environment and Conservation Council (ANZECC), the precursor to the current Environment Protection and
Heritage Council (EPHC).

In 2002 Environment Ministers agreed that national action was required in relation to waste electrical and electronic equipment. On behalf of the EPHC, a multi-jurisdictional working group, known as the Electrical Equipment Product Stewardship Sub-Group, examined the issue of waste electrical and electronic equipment and identified televisions and computers as first priorities for action as a result of their higher levels of hazardous
components relative to other types of electrical products, and the lost opportunities for conserving non-renewable resources due to products being sent to landfill. In 2008 EPHC committed to the development of a national solution to the problem of end of life televisions and computers.

In parallel with government consideration of the issues both the television and key players in the computer industries are keen to engage in large scale national action, with national regulatory support to ensure a level playing field in the market.

In this document computer and computer products are defined as including: computer displays, computer desktops and similar, computer mobile units (e.g. laptops), computer
peripherals (e.g. keyboards, mouse, hard drives, scanners, speakers, web cams, power cords, internal power supplies, external power supplies, fans, miscellaneous/other parts), personal or desktop laser and inkjet printers, and multi function devices.

While each jurisdiction has its own regulation setting out waste minimisation policies (refer to Appendix D), currently only the Australian Capital Territory (ACT) Government has a ban on disposing television screens and computers monitors in its landfill. Other jurisdictions are considering bans and a number of take-back schemes have been trialled. In addition, a number of local governments across Australia have implemented or are
considering bans or charges for disposing of e-waste in landfill. The number of responses to addressing television and computer waste, and more broadly e-waste, in Australia, demonstrates the significance of the issue to the community and the drive to take action

This document is a consultation regulatory impact statement. Its purpose is to examine the impacts of implementing consistent national arrangements for end-of-life televisions and computers. The regulatory impact statement assesses proposed options to address identified problems with end-of-life televisions and computers. This consultation regulatory impact statement does not propose to address the whole issue of end of life electrical and electronic products, but rather it is part of a proposed incremental approach. ...

The television and computer waste problem

Currently in Australia, each jurisdiction has its own waste minimisation legislation or policies. The broad powers provided to each jurisdiction by waste minimisation legislation means that there is a tangible risk that each jurisdiction will implement a different approach to the television and computer waste problem in the absence of a national approach. Due to this, Environment Protection and Heritage Council each jurisdiction has been working through the EPHC towards seeking a national solution. Specific television and computer waste responses have already begun to vary in different jurisdictions. For example the ACT has banned the disposal of computer monitors and television screens in landfill, and Victoria is trialling Byteback, a government-run computer collection and recycling scheme.

In addition, some private sector schemes have arisen to deal with the increasing volumes of waste television and computer products (e.g. Dell offers free recycling of any Dell branded equipment, and Apple offers free recycling for purchases from particular stores). However, these schemes are brand-specific so are not whole-of-waste solutions, and in addition it is not clear how easy it is for households to participate. While some television and computer waste is currently recycled, the financial value of the recycled
material resources (metals, glass, plastic, etc.) is not high enough to fund an
expansion of recycling beyond its current levels. In other words, recycling of
these products is financially unviable without government support.

Despite some government and private sector intervention, the recycling rate remains low at 9% of units reaching end of life (excluding export of used items), or 10% based on tonnage - with the remainder being landfilled and a minor proportion that are exported.

Considering whether there is a case for government intervention to improve recycling or reduce landfill of television and computers in Australia, it is important to identify the possible problems with the current situation. The following problems have been identified for stakeholder consideration:

* Conservation of non-renewable resources. ...
* Community expectations are not being met. ...
* Free-rider problem. ...
* Landfill externality costs. ...
* Landfill direct costs and opportunity cost of land. ...

In addition to the problems with the current disposal methods, there are a
number of policy factors that add to pressure for Australian governments to
address these problems. These policy pressures include:

* Australia is a signatory to the Basel Convention on the Control of the Transboundary Movements of Hazardous Waste and Their Disposal (the Basel Convention) and the Stockholm Convention on Persistent Organic Pollutants (the Stockholm Convention). ...
* international pressure from countries that have already implemented television and computer recycling schemes.

Policy objectives

The objectives of a regulatory impact statement when considering government intervention should include broad-ranging concepts that can be applied to a range of problems. More specifically relating to end of life televisions and computers should be to address the conservation of non-renewable resources; meet community expectations regarding resource
recovery and recycling; address market and regulatory failures; and avoid, where possible, any negative environmental impacts associated with waste going to landfill, while being consistent with broader government policy.

Consistent with the Council of Australian Governments’ Best Practice Regulation A Guide for Ministerial Councils and National Standard Setting Bodies (2007) (the COAG guidelines) the following specific objectives have been agreed.

Acknowledging that the above objectives will require implementation, administration and other costs, whilst generating a range of social and environmental benefits, an overriding objective in line with the COAG guidelines, will be to obtain a net benefit (benefits minus costs) for the community. This will be considered when alternative approaches to intervention are considered in a cost benefit analysis framework.

Policy options

Considering the problems identified and objectives established, a set of policy options have been identified that seek to address television and computer waste problems and wholly or partly achieve the stated objectives.

In order to identify the most feasible options, the following process was undertaken:

* identification of policy options ...
* identification of funding approaches ...
* assessment of policy and funding combinations ...
* most feasible options selected ...

Considering findings of the qualitative analysis of each policy option, the nine options for a change in government intervention and the base case that are considered worthy of further cost benefit analysis are:

* Base Case: business as usual ...

* Options 1 & 2: Co-regulatory state-based Extended Producer Responsibility (EPR) scheme – implemented as a National Environmental Protection Measure (NEPM) with an exemption if the importer belongs to an industry scheme. This scheme is assumed to be administered by an industry-run Producer Responsibility Organisation (PRO), and makes use of a regulatory safety net to encourage participation that is administered by state and territory government. Two options for industry involvement were also considered:

- Option 1: television and computer industries are jointly responsible for the collection of all products under a common PRO (including historic and orphan products).

- Option 2: television industry responsible for the collection of all products (including historic and generic). Major computer brand owners responsible for historic waste from their own brand and importers of generic computer parts and equipment are responsible for all non-branded and historic products. There are two PROs.

* Options 3 & 4: Co-regulatory Commonwealth-based EPR – with an exemption if the importer belongs to an industry scheme. This scheme is assumed to be administered by a PRO, and makes use of a regulatory safety net to encourage participation that is administered by the Australian Government. Two options for industry involvement were also considered:

- Option 3: television and computer industries are jointly responsible for the collection of all products under a common PRO (including historic and orphan products).

- Option 4: television industry responsible for the collection of all products (including historic and generic). Major computer brand owners responsible for historic waste from their own brand and importers of generic computer parts and equipment are responsible for all non-branded and historic products. There are two PROs.

* Options 5 & 6: Co-regulatory Commonwealth excise (levy) – with an exemption if the importer belongs to an industry scheme. This scheme is assumed to be administered by a PRO, and makes use of a regulatory safety net to encourage participation that is administered by the Commonwealth Government. Two options for industry involvement were also considered:

- Option 5: television and computer industries are jointly responsible for the collection of all products under a common PRO (including historic and orphan products).

- Option 6: television industry responsible for collection of all products (including historic and generic). Major computer brand owners responsible for historic waste from their own brand and importers of generic computer parts/ equipment are responsible for all non-branded and historic products. There are two PROs.

* Option 7: Mandatory Commonwealth levy with a government-run subsidy scheme for collection/recycling – a Commonwealth administered scheme whereby regulations impose a fee to be paid on all imports, and subsidies are paid to recyclers for collection/recycling of televisions and computers;

* Option 8: Mandatory import license requirement – producers must hold a license to import televisions and computers, which involves membership of an industry scheme to collect and recycle waste items (involving an industry PRO administering the scheme on behalf of importers); and

* Option 9: Mandatory state-based EPR (NEPM) – involves an industry-run PRO administering a collection/recycling scheme on behalf of importers (who are required by regulation to take part in the scheme). Administration of required regulation could be undertaken by the Australian or state or territory governments.

Cost benefit analysis of options

Analysing the costs and benefits of the identified policy options using economic Cost Benefit Analysis (CBA), indicates that the nine television and computer recycling schemes assessed in this regulatory impact statement will result in net economic benefits to society. As the CBA is based on a range of estimates and assumptions, the appraisal results provide a general view about the likely expected economic outcomes that are subject to these assumptions. Despite this, the appraisal results in an overall conclusion that the options have positive economic outcomes, with relativities between options not expected to change with amendments to key assumptions.

In addition to establishing positive net economic benefits from implementing a scheme, the cost benefit analysis also compared nine possible policy options against the status quo.

The CBA and analysis of broader considerations indicates that:

* all nine recycling policy options assessed result in net benefits, with net present values (NPVs) ranging from $517-742 billion;
* there is little differentiation between the schemes in terms of the present value of costs and benefits; and
* any differentiation has been found to be due to differing ramp up of recycling rates, and varying administration costs.

Given the closeness of the options it is preferred that the community be given the opportunity to comment freely on which option might be the preferred, hence approach in the consultation regulatory impact statement is that no individual options are recommended and all will be considered through the consultation process. ...

From: Consultation Regulatory Impact Statement: Televisions and Computers", prepared by PricewaterhouseCoopers (PwC) in association with Hyder Consulting (Hyder) for the Environment Protection and Heritage Council (EPHC), July 2009).

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