Submitted by admin on Thu, 2010-03-25 14:37
4.9(1)
eWaste refers to Waste Electrical and Electronic Equipment (WEEE). This waste stream is relatively new, rapidly growing, and in some cases highly hazardous due to heavy metals content. There are currently no reliable statistics for the amount of eWaste generated or recycled. With the increase of consumerism and the rise of the information age, eWaste will continue growing exponentially, and rapidly become a major waste challenge. WEEE can contain over one thousand different substances, many of which are toxic and some that have a high market value when extracted. There are seven recognized sub types of eWaste as per the Waste Classification System. Lighting equipment is one of these seven types and will be considered as a separate waste stream due to the specific mercury content issue and related IndWMP being prepared specifically for this waste stream. The other six sub types should be considered individually within the eWaste stream and where appropriate individual measures for each sub type may be required.
4.9(2)
In terms of implementing the waste hierarchy, the main challenge lies in separating this waste from general waste to facilitate safe and economically sustainable recycling of this waste stream.
4.9(3)
Informal recycling of eWaste is relatively prevalent, but often done without safety equipment, resulting in potential harm to health, and contamination of the recycling site, as well as the release of noxious fumes through the burning of plastic to access the valuable metals inside the equipment. Formal recycling is typically a partially mechanized process which separates materials, whilst WEEE is often dismantled by hand and then separated before shredding. Some mechanized processes do not necessarily allow for re-use or refurbishment, as the whole object is put through a shredder, and the shredded output is then mechanically separated using water, air or magnetism. The separated shredded plastics and metals are then sent for reprocessing as recyclates.
4.9(4)
In July 2008, the eWaste Association of South Africa (EWASA), a section 21 company, was established to set up an environmentally sound eWaste management system, utilizing various programmes and networks. Membership of EWASA is R2000 per year for recyclers.
4.9(5)
The two major emerging initiatives are voluntary take-back facilities at retailers which in turn increases recyclate availability, and a recycling fee on imported goods which may result in eWaste. This levy will be managed and regulated via industry. At present some retailers are agreeing to voluntary take-back facilities. Such facilities at electrical and electronic goods retailers should be mandatory and subject to an IndWMP for the eWaste industry.
4.9(6)
EWASA will form a section 21 company to manage a 10% recycling fee charged on all imported goods which will result in eWaste. At present it is a voluntary fee and requires the manufacturer to declare imports to EWASA, who will then compare the data with customs to ensure the correct amount is paid. Whilst several large electrical and electronic brands have agreed to this voluntary scheme, it should be formalized in terms of an IndWMP, and be made universally applicable through mandatory measures, to ensure that there are no free-riders within the industry.
4.9(7)
The use of take-back facilities is at present voluntary, meaning some eWaste still goes to landfill or the informal recycling process. DEA will make it a legal requirement for consumers to utilize these take-back facilities through regulations requiring producers and importers of WEEE to develop IndWMPs or to register with approved plans.
4.9(8)
DEA will develop standards for the storage, treatment and disposal of electronic waste as part of the process to develop norms standards in terms of section 7(1)(c) of the Waste Act.
4.9(9)
Further research must be undertaken by industry regarding the appropriate measures to protect the health and safety of the informal recyclers currently handling eWaste while seeking to protect their livelihoods. At present EWASA membership is likely to be too expensive for most informal recyclers, and therefore ways of redressing disincentives such as this and the limited accessibility of EWASA schemes (such as the online booking system which facilitates recyclers ‘booking’ the retailers that they wish to collect waste goods from) should be developed by industry.
4.9(10)
The SAWIS categories have been expanded to include 7 categories for reporting on e-waste.
4.9(11)
The measures set out in this section are to be contained within an IndWMP, produced by industry. The IndWMP will provide for mandatory take-back facilities at retailers, the process of formalizing the informal recycling practices, and the reporting requirements to the SAWIS.
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Comments
eWASA comments
Wile we appreciate that the authors noted the progress eWASA made we ask that as this is a strategy document detail such as percentages and rand value is left open for discussion in the IndWMP, giving the industry time to agree on such measures. We would welcome regulatory support to ensure that there are no free riders in the system and will describe in detail how this can be achieved in the IndWMP. eWASA has developed Technical Guidelines for Dismantlers and recyclers of Electrical and Electronic Equipment and would submit that these be part of the standards developing process.
Microsoft EOC Comments on 4.9 eWaste
Microsoft fully supports extended producer responsibility whereby producers take responsibility for end-of-life recycling of products. Microsoft however cannot support the proposal contained in sections 4.9(5) and 4.9(6) for a 10% recycling levy on all imported electronic and electrical products because it is an indiscriminate and unfair measure.
Microsoft proposes the actual cost of recycling waste electrical and electronics discarded by consumers be borne by producers in proportion to their individual market share express by weight. This approach has worked well in Europe over the past number of years. It eliminates the need for a visible fee and allows producers to internalise recycling costs. And it ensures costs borne by producers reflect the actual cost of recycling provided competitive take-back systems are operational.
Furthermore, Microsoft believes that producers should where possible take individual responsibility (IPR) for the recycling of their products and that such recycling should be recognised as contributing to a producer’s obligation.
Comment on section 4.9 by Dell South Africa
Dell expresses concern to the impression given in sections 4.9(5) and 4.9(6) that some producers are aware of and have agreed to the proposal as outlined for a 10% recycling fee to be levied on all imported goods when that is not the case. The proposed 10% import levy is vastly disproportionate to the actual cost of recycling.
Dell has global experience in the establishment and running of producer take back systems and in the treatment of e-waste and in all cases has seen monopolistic take back systems increase cost for producers through lack of competition and demonstrate little or no benefit to the producer or consumer.
Dell has signed a memorandum of understanding which outlines principles of a competitive and equitable take back structure. Producers should pay for their market share of waste collected and treated by their appointed scheme. Producers should also be able to take back products using their own collection systems and these volumes be counted towards their own obligation thus embuing the principles of collective and individual producer responsibility. All producers should be able to demonstrate their Take Back scheme in operation or be obliged to join an appropriate take back scheme to prevent ‘free riders’ and avoid cross subsidisation of the treatment across collection categories.
The cost of recycling or managing E-Waste should not be recovered through the use of Visible Fees or a 10% import levy, producers should cover the cost of recycling through the internalization of recycling costs ensuring that these costs reflect the actual costs incurred for the volumes of products which are recycled.
4.9 eWaste
Reference to subsections 4.9(5) and 4.9(6) - Concern is raised due to the impression created that a 10% recycling fee could be levied on imports and that certain producers have agreed to these arrangement which is incorrect.
HP South Africa along with some other producers have entered into similar Memorandum of Understandings with eWASA where it is made clear that a competitive take back structure will be implemented whereby obligation calculations will be performed separate to recycling operations. Producer obligation will be determined based on individual market share. The producer will then fulfill the obligation by entering into a contract with an approved recycler. The approved recycler will only be paid for actual goods collected and recycled according to the producer’s individual obligation.