Comments on the draft National Waste Management Strategy

Dear Madam/Sir, 1. Nokia believes that mobile connectivity has become a key enabler in building sustainable and innovative societies. Mobility and the ICT industry improve the lives of people by providing better access to economic opportunities, healthcare, knowledge and many value-added services. Nokia further believes that it is part of our corporate responsibility to support the building of a recycling society, and we therefore welcome South Africa’s efforts in establishing a sustainable take back and recycling strategy, infrastructure and management scheme. 2. Nokia has been operating the world’s largest voluntary mobile phone recycling scheme for years (with 5,000 collection points in over 85 countries) and always taken into consideration the highest international standards for recycling. In South Africa, Nokia has 22 collection points and is constantly expanding the network. Awareness building is also a key focus: in March-April 2010, Nokia organized an environmental campaign in cooperation with 15 South African radio stations, to encourage communities to be environmentally aware. Nokia has therefore gained global experience in the establishment and running of producer take back schemes and management of mobile phones and accessories. We have learned that competition between different recycling schemes can ensure that the schemes are run as efficiently as possible, both in terms of economical performance and user friendliness. 3. Nokia is concerned about the negative impact of proposed excess duties arising from the NWMS proposal. Such excess duties raise the total cost of ownership of products for end-consumers (for example for a mobile phone) and therefore create barriers of entry which prevent people from getting access to means of communication, value-added services for service deprived communities (banking, etc.), etc. People with lower incomes are the most negatively impacted when such barriers are created. Additionally, higher barriers will promote grey imports and smuggling of goods and support strengthening of grey economy. 4. With reference to the published draft NWMS and specifically to the section related to the management of e-waste and batteries (4.9 and 4.10), Nokia expresses its strong concern. The 10% recycling fee proposed by EWASA, to be charged based on the value of the imported goods into the country, is greatly disproportionate to the actual cost of recycling. From the long term experience of collaborating with the network of approved recycling companies, Nokia has been able to determine that with products such as mobile phones, the high content of valuable materials that can be regained during the process of recycling roughly covers costs of recycling. Nokia believes that balanced cost management needs to be put in place instead of a standard fixed fee for all categories of e-waste. We believe that a proportionate and transparent cost allocation for specific categories of e-waste and between all the relevant actors is needed. 5. In summary: Nokia recommends that a transparent recycling strategy be put in place, in which all stakeholders along the value chain (meaning not only producers, but also retailers, distributors, operators, etc.) are made responsible to carry their share of the costs for a sustainable solution, so that there are no “free riders”. Nokia feels obliged to carry its share of costs arising from the management of Nokia products at the end of their life. However Nokia strongly recommends for the financial obligation to be based on the actual cost of recycling of its products, and not on fixed fees. Nokia appreciates the commitment of the SA government in developing a sustainable solution. Therefore Nokia wishes to share with the government and the relevant stakeholders of the value chain its wealth of experience to contribute to the build up of a holistic recycling society in South Africa. Yours Sincerely, Jussi Hinkkanen Vice President, Government Affairs and Business Environment Nokia Middle East and Africa The Core, 5th floor, Cnr Leeukop & Kikuyu Roads Sunninghill, Johannesburg 2157 South Africa