A fundamentally sound scheme that needs to be reset and sharply enforced
The National Television and Computer Recycling Scheme (NTCRS) now boasts over 600 drop-off and collection services nationwide and has collected and recycled well over 80,000 tonnes since its inception in 2012. Much of this funded by OEMs, brands and importers operating through five Co-regulatory Arrangements. It is vital to note that a large number of local councils and retailers have also supported this work through significant in-kind contributions such as publicity and advertising, drop-off sites and related infrastructure.
The vast majority of end-of-life televisions and computers were landfilled prior to the enactment of the Product Stewardship Act 2011. Only 10,000 tonnes being recycled over 2007-2008 in the absence of the NTCRS.
The Act and the NTCRS are in themselves important components of the National Waste Policy, and they provide the context for improved levels of waste avoidance and resource recovery.
There are however several issues and anomalies that must be acknowledged and corrected by the Australian Government, Co-regulatory Arrangements and other stakeholders to further maximise the environmental benefits. Anyone involved with solution-oriented policy reform and regulatory instruments will know this. It is typical, expected and unavoidable in any establishment phase. The EU Waste Electrical and Electronic Equipment (WEEE) Directive went through very similar phases with numerous adjustments and improvements.
Many local councils overlooked or misled?
There are still many local councils across Australia that have missed out on benefiting from the NTCRS, and this is an area requiring urgent rectification. Access and equity needs to be more effectively addressed by revising the Reasonable Access requirements and ensuring that enthusiastic councils are not overlooked by the Co-regulatory Arrangements on the basis of the ‘high transport costs’ involved in servicing regional and remotes areas.
The cost-shifting objective inherent in the principles of Product Stewardship and Extended Producer Responsibility has yet to fully mature in reality due to the mismatch between the targets and the volume of television and computer waste generated. Unfortunately there are also councils that have had services withdrawn or restricted by their ‘partner’ Co-regulatory Arrangements.
The cost shifting exercise must be made an ongoing priority under the NTCRS if we are to see the full range of e-waste related externalities genuinely addressed.
Would increased targets eliminate stockpiles?
A revised target of 50% to 55% has the potential to virtually eliminate the risk of stockpiles and councils having services withdrawn. This would not however sit comfortably with many OEMS and brands and is a legitimate cost issue.
An increased target may also contribute to improving the viability and competitiveness of social enterprises wishing to participate the NTCRS. The two years of experience to date is sufficient to enable more accurate forecasting of waste arising and therefore more appropriate targets, particularly given that the digital switch has now passed. The trajectory of targets can thereafter be optimised to reflect future imports of new products and the lag in waste arising.
The fact that Australia can have a national e-waste scheme which refuses to collect consolidated volumes of material ready for collection at councils, is not only puzzling, it is socially and environmentally problematic. Straightforward amendments to the Regulations are required, and provide the Government with the opportunity to make meaningful improvements to the NTCRS. Environment Minister Greg Hunt is perfectly placed to act swiftly and with justification to adjust the NTCRS and enhance Australia’s e-waste collection and recycling program.
Well-meaning critics or under-performing service providers?
Some of the NTCRS issues (but not all) that have attracted media attention have been raised by entities who have sought to benefit commercially from the NTCRS, which raises questions about the veracity of the criticism given the broader context and intent of the Product Stewardship (Televisions and Computers) Regulations i.e. the diversion of potentially hazardous television and computer waste from landfill, and an increase in the recovery of useable materials.
Is the failure of these entities to ‘succeed’ or benefit under the NTCRS a reflection of the scheme itself or their inability to conduct adequate due diligence in relation to contracts, agreements and financial forecasting? This is a complex and contentious space laden with much emotive argument. It also highlights that much more can be done by Co-regulatory Arrangements to effectively involve social enterprises in NTCRS operations, while still delivering on the primary environmental goals.
Conversely, some in industry will argue that regulatory instruments such as the Product Stewardship (Televisions and Computers) Regulations, were not created to protect service providers or to guarantee the supply of volume to any processor. Watch this space as vested interests from all quarters continue to intensify their lobbying and media activities. As we all know there are multiple sides to any issue; a more objective level of analysis is what has been missing to date.
Ten-point plan to re-set the NTCRS
Most importantly we need to get on with the process of correcting and adjusting the NTCRS so we can address the typical teething problems of any new regulatory instrument.
There is a role for all of us to help shape and improve the scheme. Collaboration is key here. Having contributed to the development of both the Act and the NTCRS, I can see obvious and timely actions that can be addressed and incorporated into Mk 2 of the NTCRS:
- Increase the level of monitoring and enforcement
The level of policing to date by the Commonwealth Government Regulator has not been overly transparent, which in turn is undermining public confidence, especially among local councils and social enterprise recyclers. In addition, State agencies and EPAs must also increase monitoring and enforcement of collectors and recyclers to ensure that NTCRS related activities and operations are in compliance with State regulations, licensing and permitting.
- Introduce collection targets for each State and Territory
The current single figure national target is an economic disincentive for Co-regulatory Arrangements to ensure effective and adequate collections in some States, especially Western Australia where many communities are not serviced, despite the scheme’s Reasonable Access requirements. Collection targets allocated to each State and Territory will positively compel Co-regulatory Arrangements to pro-actively secure higher volumes on a more equitable basis nationwide.
- Revise collection targets over the next three years
A stiffening of the collection targets over the short-term has the potential to address the current situation of ‘surplus-to-compliance’ volumes and stockpiles. A revised target of 50% to 55% may also reduce the risk of councils having services withdrawn.
- Mandate appropriate standards in the Regulations
The relatively new AS/NZS 5377:2013 related to collection, storage, transport and treatment of end-of-life electrical and electronic equipment should be cited in the Regulations and be a mandatory requirement for all Co-regulatory Arrangements. Independent auditing against this standard is also essential. This will harmonise performance objectives and outcomes as well as raise the performance bar for suppliers, providers and collection partners operating under the NTCRS.
- Improve the quality of community awareness and education activities
The quality of community awareness and education activities associated with the NTCRS has been superficial at best. More education and less PR needed. Impactful consumer campaigns combined with genuine schools education programs are needed to achieve the desired behaviour change and ultimately meet the increasing collection targets.
- Increase collaboration between Co-regulatory Arrangements
The Commonwealth Government Regulator should encourage and/or compel Co-regulatory Arrangements to work more cooperatively on servicing regional and remote areas of Australia. Greater collaboration to improve community awareness and common messaging is also urgently required. Greater collaboration focused on involving social enterprise recyclers is also overdue.
- Increase the quality of public reporting by the Co-regulatory Arrangements
While some reporting and documents from some Co-regulatory Arrangements features important detail and statistics, the overall quality of annual reports to date has been breathtakingly poor and unacceptable under a regulated scheme.
- Increase the quality of public reporting by the Commonwealth Government Regulator
The depth and detail associated with reporting from the Government needs to improve and expand to provide greater visibility of performance and challenges, as well as flag future activities relevant to the NTCRS.
- More accurate calculation of Scheme and Co-regulatory targets
A more collaborative approach is required between the Regulator, Co-regulatory Arrangements and Liable Parties in order to arrive at acceptable conversion factors that are recognised by both industry and Government. These calculations must be revised regularly and reflect new technologies and associated form factors.
- Introduce product reuse objectives
Consistent with the waste management hierarchy, it is timely to demonstrate some measurable commitment to waste avoidance and reuse principles within the context of the NTCRS. The Commonwealth Government Regulator should commence focused discussions with Co-regulatory Arrangements on where and how to best integrate reuse and product life extension objectives as part of future schemes operations and activities, even if this commences with more effective consumer education programs.
Adjusting and optimising the NTCRS need not be onerous or process-bound. Rapid adoption of the above points will not only serve to re-set and improve the scheme, it will allow Minister Hunt the opportunity to demonstrate some decisive action and the required amendments to the Product Stewardship (Televisions and Computers) Regulations in response to community and industry concerns.
Anything less would fail to meet community expectations. It would also overlook the millions of dollars invested to date by environmentally committed IT and consumer electronics companies.
By correcting the scheme in a timely manner, the Australian Government is perfectly placed to work with Co-regulatory Arrangements, Councils, providers and the public to ensure the delivery of a national e-waste program that is environmentally necessary, commercially responsible and socially desirable.
John Gertsakis – Chief Sustainability Officer
- Increase the level of monitoring and enforcement
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