By 2010, an estimated 184,000 tonnes of selected used electrical and electronics products (e-waste) will be discarded each year in Canada. Those materials will be comprised of more than 45,000 tonnes of glass, 4,500 tonnes of aluminum, 48,000 tonnes of ferrous metals, 39,000 tonnes of plastics plus various quantities of lead, cadmium, mercury and combinations of various chemicals and compounds, including the controversial polybrominated diphenyl ethers (PBDEs), a flame retardant found in many plastic components.
Maine, California, Alberta and Ontario (which together represent close to 50 million people) have implemented (or are close to implementing) legislation or regulations to divert this tide of e-waste from landfill. Some states are implementing bans on the disposal of certain items such as cathode ray tubes. Certain provinces (such as Manitoba, British Columbia, Nova Scotia and Saskatchewan) are in various stages of public consultation prior to implementation of programs to capture, reuse and recycle e-waste products.
Though e-waste may only represent one to two per cent of all municipal solid waste disposed, from a lifecycle perspective used electronics equipment can be much more significant than other waste products. In Europe, recognition of this fact has led to the development of restrictions on hazardous substances (RoHS) through the RoHS Directive. Japan has opted for similar restrictions. The United States and Canada have yet to adopt similar requirements, although things are evolving.
One of the most disturbing aspects of e-waste is the growing volume making its way to developing countries such as China where well-documented rudimentary recycling practices take place that include extremely poor labor practices and environmental contamination. Unskilled (sometimes underage) workers disassemble the products and suffer exposure to toxins (e.g., from burning plastic wire covering to extract valuable copper). That’s one reason why some policymakers are designing programs that promote extended producer responsibility (EPR) so that brand owners redesign their equipment to be toxin-free in the first place, and more easily dismantled and recycled.
Nova Scotia has produced draft regulations for e-waste products with the intent to encompass complete EPR. The province’s program builds upon the foundations laid out by the Canadian Council of Ministers of the Environment (CCME) in its twelve guiding principles for electronic product stewardship. Nova Scotia seeks a program in which brand owners (manufacturers) shoulder the full burden of the program. The collection and 3Rs program for all designated e-waste is to be universal, and design for toxic material reduction and recycling is to be incorporated into products. Brand owners are to pay for the program without charging an extra fee from the consumer. This last point is controversial but is considered important to force “cost internalization” on the part of brand owners/manufacturers. (For more detail, see Editorial, page 4.)
The proposed program initially targets TVs, computers, laptops, keyboards, mouse, cables, monitors, printers, scanners, audio and video playback and recording systems, telephones, fax machines, cell phones, and electronic game equipment. While not as extensive as Europe’s WEEE Directive, the intent is to capture the majority of e-waste products and add to the list at a later date.
One of the most controversial issues surrounding this program is the requirement for cost internalization. Nova Scotia has asked brand owners to shoulder the full costs of the program, without external fees for the consumer. To date, brand owners and retailers are split on the issue, some indicating they would like external fees and others stating they don’t want external fees. There are many more arguments on both sides of the issue, all with legitimate points. In the end, whether an external fee is applied or not, Nova Scotia is determined to move forward to capture e-waste products from the waste stream for reuse and recycling.
Nova Scotia’s program is not finalized at the time of this writing (it will be complete sometime this spring or summer) but as drafted will affect both brand owners and retailers. Retailers will be required to:
1. Ensure that the brand owners of affected products they sell are covered under an approved stewardship program. If the brand owner is not registered, the business will not be able to sell its products.
2. Provide information at the point of sale on where customers can take their old products for recycling.
Under the proposed program, brand owners are required to register with the Resource Recovery Fund Board (RRFB). Once registered, each brand owner will be required to participate in the program in one of two ways:
Option One: The business must submit a written proposal to the Minister of Environment and Labour for approval. The proposal must include how the brand owner will:
* Cover the costs of the program without charging the customer an extra fee, and provide a written plan for how they intend to do this. (They may increase the cost of their products, but must not charge an extra fee to their customers);
* Provide collection without charging consumers when they return products for recycling;
* Run an education and awareness program (to inform consumers on how to participate and when they need to do so);
* Implement a “design for the environment” program that eliminates environmentally harmful materials and ensures the products (where possible) are reused and/or recycled.
Business that choose this option must provide universal access to this program. This means their business must accept electronic products for recycling from any brand owner — not just their own. In essence, under this option, the business would be a recycling depot.
Option Two: A business can contract with RRFB Nova Scotia to do all of the items outlined in Option One, including the design for the environment part. Under this option, businesses will probably be required to report to RRFB Nova Scotia on a regular basis how much product is sold (to determine the cost of managing the program to the business). It’s estimated that it may cost about $30 per computer system sold (computer, monitor, printer and accessories) to run this program.
The Nova Scotia paint recycling program is probably the most similar to the one proposed for electronics. For that program, all brand owners of paint use the equivalent of Option Two: RRFB Nova Scotia manages the program for them. In that program, customers return used paint to any one of the Enviro-Depots in the province. Brand owners pay RRFB Nova Scotia to manage the program.
Barry Friesen, P.Eng. is solid waste resource manager with Nova Scotia’s Department of Environment and Labour. Contact Barry at firstname.lastname@example.org