National E-waste Product Stewardship Scheme Local Government Proposal

Background to this Submission Through the National Waste Policy, the Commonwealth Government has made a commitment to put in place product stewardship schemes by 2012 to provide !or the impacts o! a product being responsibly managed during and at end o! li!e" #200$, p% $&% The disposal o! e'waste has been identi!ied as a (ey issue, and there!ore, will be the sub)ect o! a national product stewardship scheme% *iscussions have already begun in regards to the shape this scheme may ta(e% The +unicipal Waste ,dvisory Council #+W,C& has a representative on the -ta(eholder .e!erence Group !or the Product -tewardship -cheme /mplementation Wor(ing Group% +W,C would li(e to ta(e this opportunity to present an outline o! how Western ,ustralian #W,& 0ocal Governments would e1pect to see the National Product -tewardship -cheme apply in W,% This paper presents an outline o! the (ey components that 0ocal Governments e1pect to see in an e' waste scheme, as well as highlighting the speci!ic issues which have been associated with past product stewardship schemes% Key ecommendations W, 0ocal Governments support the 21tended Producer .esponsibility approach% There are, however, three (ey areas that 0ocal Governments e1pect will be covered in the development o! the National -chemes3 Key Recommendation 1: That the National 2'waste Product -tewardship -cheme has a clear aim, sets tangible targets and clearly de!ines the roles and responsibilities o! each sta(eholder group% Key Recommendation 2: *ue to 0ocal Governments current involvement in e'waste collection, the Commonwealth Government involves 0ocal Government in negotiations regarding the content and promotion o! the National 2'waste Product -tewardship -cheme% Key Recommendation 3: That the Commonwealth Government provide a long'term commitment to the National 2'waste Product -tewardship -cheme% !urrent ole o" Local Government The current role 0ocal Government in the collection and disposal o! e'waste is a signi!icant one% /n W, some 0ocal Governments and .egional Councils are collecting e'waste% The cost to collect and then recycle this material is substantial% 4ne e1ample is the City o! 5unbury, a regional centre #16,768 households, population 92,:81 and an area o! 61%2 (m 2&% The City o! 5unbury has
National 2'waste Product -tewardship Program W,0G, Proposal 4ctober 2010 1

identi!ied community concern and the increase in electronic waste as the drivers behind the need to provide a service !or e'waste recycling% The City is currently collecting appro1imately one sea container !ull o! e'waste every three wee(s #:7 tonnes per year&; at a cost o! <72,000 per annum% This cost is !or recycling only and does not include the sta!! time and associated costs !or the 0ocal Government% /n a survey o! eight 0ocal Government and .egional Council owned !acilities in the Perth +etropolitan area covering the si1 months preceding +ay 2010, highlighted the signi!icant costs to 0ocal Government !or the collection and recycling o! this material is high% /n )ust si1 months, metropolitan 0ocal Governments and .egional Councils collected almost 270 tonnes o! e'waste, with a cost to recycle this material to 0ocal Governments o! over <200,000% The ma)ority o! these collections were not advertised, indicating the interest and e1pectation !rom the community !or the role o! 0ocal Government in collecting this material% The recycling costs does not include the sta!!ing costs o! 0ocal Government o!!icers !or the segregation=sorting o! these materials% 0ocal Governments and .egional Councils have also hosted the ,pple e'waste collections% /n 2010, the ,pple !unded collection days collected appro1imately 210 tonnes o! material > in 2 days at eight sites around the metropolitan area% ?or this event 0ocal Governments and .egional Councils provided the sites and !unding !or promotion #appro1imately <87,000&% #uture ole o" Local Government There is an e1pectation !rom the community that 0ocal Government will collect e'waste% /t is o! concern to 0ocal Government that there may be an e1pectation !rom Commonwealth and -tate Governments that 0ocal Government will continue to be the sole provider o! e'waste collections% ?or 0ocal Government to collect e'waste there are signi!icant costs and impacts, not only the costs to recycle material but the sta!! time and site space to underta(e the collections% 0arge increases in tonnages would e!!ect the management o! collection sites% 0ocal Government may not, within their current arrangements, be able to manage substantial increases in tonnage o! e'waste% Product -tewardship implies that industry will ta(e a greater role in the management o! e'waste% /t is 0ocal Governments e1pectation that industry will ta(e a role in not only !unding the recycling o! e'waste but involvement in #and !unding& the collection o! the material% There!ore, 0ocal Government has a strong e1pectation that there will be negotiations over the identi!ication o! parties responsible !or each aspect o! the -cheme, as well as the structure and !unding !or the -cheme% ?or e1ample, negotiation on the use o! 0ocal Government sites !or collection, cost recovery !or 0ocal Government collection sites, promotion strategies and activities and identi!ication o! other collection sites #industry run&% 0ocal Governments have also identi!ied that there has to be a !irm and long term commitment to the Product -tewardship scheme% There will be a substantial impact on 0ocal Government i! the

National 2'waste Product -tewardship Program W,0G, Proposal 4ctober 2010

-cheme is stopped% 2specially when the e1pectations o!, and there!ore the material !rom, the community has increased in regards to the collection and disposal o! e'waste% Principles o" E$tended Producer esponsibility The W,0G, Policy -tatement on 21tended Producer .esponsibility outlines 0ocal Government"s support !or the 21tended Producer .esponsibility approach as an important part o! achieving the vision o! a @ero waste society% 0ocal Government considers that the 21tended Producer .esponsibility approach can provide e!!ective tools to advance the (ey outcomes reAuired by this vision% 0ocal Government considers that these (ey outcomes are3 Clear, sensible and e!!ective designations o! responsibility !or the management o! li!ecycle impacts o! products /mproved valuation, pricing and incentive mechanisms Greater investment in in!rastructure and research and development Greater transparency and accountability% /n its role as a service provider, 0ocal Government will assess proposed 21tended Producer .esponsibility schemes with re!erence to the !ollowing criteria"3 .e!lect appropriate priorities -et clear ob)ectives and targets 2stablish clear responsibilities Can be implemented in a timely !ashion ,pportion costs appropriately Give due consideration to the speci!ic characteristics o! the waste or product type -upport claims with re!erence to credible evidence% 0ocal Government e1pects that an 21tended Producer .esponsibility scheme !or e'waste will include3 A clear aim with regards to what the Scheme is proposing to achieve. ?or e1ample, is the aim to achieve recovery rate targets across the country or in selected areasB What materials will be included in the recovery rateB ,re there aims regarding energy e!!iciency, pollution mitigation, reduction in ha@ardous materials to land!ill, resource e!!iciency etcB Negotiation with Local Government% /t cannot be assumed that 0ocal Governments have the capacity to continue to be the only collection point !or material, or that 0ocal Governments will start collecting material% The sector also e1pects to be consulted in regards to the distribution o! responsibility !or collection and disposal% A long-term commitment to the Scheme from the State and Commonwealth Governments. 0ong'term and=or ongoing !unding will ensure guaranteed collection% This commitment will also address the concern !rom the sector that, once the -cheme #and there!ore !unding& ceases operation 0ocal Governments will be caught paying !or the collection o! increased e'waste% Community engagement.

National 2'waste Product -tewardship Program W,0G, Proposal 4ctober 2010

There is an e1pectation that the -cheme will involve community education as well as promotion% Community engagement will go some way to ensure that the public will consider the implications o! e'waste% No net cost to Local Government. The current cost to 0ocal Government !or the collection o! e'waste is already signi!icant% There is an e1pectation that the !unding !or all e1isting and new programs will be adeAuately covered by the -cheme and operational costs will also be covered% This is o! particular relevance when it is e1pected that the amount o! collected material will increase as a result o! the -cheme% /n addition, it is e1pected that the -cheme will provide support !or new collection in!rastructure%

isks 0ocal Government supports the 21tended Producer .esponsibility approach, however, the sector recommends that the -cheme clearly outlines responsibilities, particularly in regards to the running, administering and collecting !unding !or the -cheme% The !ollowing e1amples highlight a number o! issues that can occur with poorly de!ined product stewardship schemes, in particular, the ris(s associated with schemes that are not supported !ully and inadeAuately designed% Product Stewardship for Used il Scheme 21perience with e1isting product stewardship schemes, such as the Product -tewardship !or Csed 4il #P-4& -cheme, indicates that problems can arise when producers do not have a practical interest in the material collected through a scheme, where governments are in the position o! being responsible" !or the disposal o! this waste and where there is a limited mar(et !or materials% 0ocal Governments are concerned that the product stewardship philosophy does not adeAuately resolve the issue o! shared responsibility !or product disposal% ?or e1ample, in the case o! the P-4, it is assumed that 0ocal Government will be responsible !or the disposal o! products% This approach does not provide compelling drivers !or signi!icant change in producer or consumer behaviour% ?or e1ample, i! producers ta(e some responsibility !or their products at end'o!'li!e, they acAuire a direct incentive to ma1imise the ease and a!!ordability o! discharging that responsibility% The current P-4 arrangements have lead to a situation in W, where mar(et !ailure has occurred in regards to used oil% 4il recovery has increased, however, with no mar(et development or responsible industry, 0ocal Government has been le!t with increasing stoc(piles o! oil and no methods o! disposal% Currently 0ocal Governments are paying !or the recycling o! used motor oil% This situation is not the case in other states, where su!!icient volumes and mar(et options mean !ree collection has continued% !rum"US#$% *rum+C-T2. is an industry'run scheme where the collection and recycling o! the material is organised by industry #and the material collected at 0ocal Government sites&% ,s industry runs the scheme, responsibility lies with them to organise the recycling and ensure that this occurs% !oncluding Points
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0ocal Governments e1pect that the -cheme will be guided by a clear aim that will outline what the -cheme is attempting to achieve, as well as what areas will be covered% 0ocal Government plays a signi!icant role in the collection and disposal o! e'waste% There is a concern, however, that Commonwealth and -tate Governments may assume that 0ocal Governments will continue to collect this material, without consideration !or the potential impacts on 0ocal Governments% 0ocal Governments e1pect that the Commonwealth Government and industry will negotiate with 0ocal Government in regards to the role it plays in the collection o! this waste, rather than assuming that they will carry out this tas(% 0ocal Governments support a scheme driven by industry, and e1pect that their role in the scheme be determined through negotiation, rather than by de!ault% There are also considerable ris(s to the success o! the -cheme i! the aim and the responsible parties are not clearly de!ined, as seen in the case o! the Product -tewardship !or Csed 4il #P-4& -cheme, where it is product disposal is le!t entirely to mar(et !orces% The mar(ets !or the products collected through the scheme need to be considered% /ndustry cannot assume that the mar(et !or products will be the same nation wide or over time% The recent Global ?inancial Crisis had a signi!icant impact on the recycling mar(et !or many products% Contingency planning and ris( management !or the end mar(ets !or products need to be care!ully considered as this presents a si@eable ris( to the -cheme% There is also an e1pectation !rom the sector that a long'term commitment !rom the Commonwealth Government in regards to the running o! the -cheme is given to ensure that 0ocal Governments are not le!t without !unding or support when the -cheme ends% This is o! particular concern when there is an e1pectation that the -cheme will result in an increase in material collected% Currently, 0ocal Governments are paying signi!icant amounts in order to provide an e'waste collection and recycling service !or their residents% 0ocal Governments e1pect that, under a product stewardship scheme, these costs will be covered% e"erences 2nvironment Protection and Deritage Council 200$, National &aste Policy' Less waste( more resources% Commonwealth Government o! ,ustralia%

National 2'waste Product -tewardship Program W,0G, Proposal 4ctober 2010