10% Recycling fee to be levied on all imported goods

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.