Transcript Obsolete Technologies and Sustainability: The Regulatory

OBSOLETE ELECTRONICS AND SUSTAINABILITY
The Regulatory Challenges of E-waste Disposal
Sabaa Khan, LL.M., LL.B.
Barreau du Quebec
Associate Fellow, Centre for International Sustainable Development Law
[email protected]
Part 1. E-wastes under International Environmental Policy
Hazards of electronic waste
Controversial international
business practices
Restricting the free trade of ewaste
• Why are electronics problematic at their end-of-life?
• How should we manage e-wastes?
• Environmental injustice claims
• Human rights implications
• Basel Convention and Basel Ban Amendment
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Part 2. Extended Producer Responsibility (EPR) Policies
GREEN DESIGN
China WEEE and
RoHS
Produce
EU law: WEEE and
RoHS Directives
Recover Consume
United States &
Canadian approach
Japan WEEE and
RoHS policies
Sustainable Production
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ELECTRONIC REVOLUTION
communication • security • health • culture
mobility • food • education
+
PLANNED OBSOLESCENCE
+
P E R VA S I V E C O M P U T I N G
40 million tonnes of WASTE ELECTRONICAL AND ELECTRONIC EQUIPMENT generated annually
(UNU, 2007)
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Any appliance using an electric power supply that has reached its end-of-life. (OECD, 2001)
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Components contain highly toxic substances. (Cadmium, lead, barium, chromium,
mercury, brominated flame retardants +…)
Landfilling and incineration are harmful to human and environmental health.
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Electronics should be recycled:
Valuable materials recovered, toxins safely disposed.
Disposal streams:
Reuse/donate/store
Commercial recycler
Curbside discard
Capital-intensive & not
always publicly funded.
Not a viable business
for small-scale
collectors and
recyclers.
Stringent environmental
and occupational health
and safety regulations
to follow in the EU,
Canada, US. (e.g.
filtration of gas
emissions, treatment of
effluents, monitoring
and control of worker
exposure to
byproducts).
Source: Tess-Amm
Source: Swiss E-waste Competence
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Most E-waste is Exported for Disposal, Recycling and Re-Use
India, P. Tewari
Ghana, BAN
Brazilian Port, UK Times
Exporter incentives
China, BAN
Importer incentives
Accountability-free, physically and financially
efficient.
Manufacturing industries need continuous supply
of raw materials.
Profitable: collection charges imposed on
consumers, sales revenue from foreign waste
dealers
(approx. USD 14.7 billion by 2015).
Rapidly growing used electronics markets,
especially in Africa.
Escapes NIMBY concerns, environmental
regulations.
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Facilitators:
Poverty
Lack of Environmental Regulation
Lax Enforcement
Corruption
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S.Khan, Obsolete Electronics &
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2010 Dayaneni and Doucette (2005)
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ENVIRONMENTAL & HEALTH EFFECTS OF
INTERNATIONAL E-WASTE FLOWS
Externalization of pollution
Ocean pollution (cargo shipping)
Human and environmental contamination in
e-waste processing villages
(e.g. Guiyu, China: food markets, school
yards, waterways, cancer, respiratory illness,
birth defects, neurological disorders.)
Smelters
Lead-bearing scrap recycled by smelting into elemental lead or alloys.
Chinese children’s blood lead levels are 4x higher than children in the
US.
Contaminated products made from E-waste
E-waste a possible source material for children’s jewelry sold in the U.S. (J.D. Weidenhammer, 2007)
Toxic levels of cadmium increasingly found in toys & jewellery sold internationally.
E-waste contaminated agri-food imports from China
e.g. Taizhou City (Zhejiang province) the “land of fish & rice” and electromechanical
industries. Rice crops high in lead and cadmium, daily intake could cause detrimental
health hazards to consumers. (J.Fu et al., 2008)
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How do e-waste trade flows impact human rights?
The Right to Life
The Right to Health
The Right to a Healthy
Environment
Fundamental Labour
Rights
•UDHR
•Stockholm Declaration (UNCHE, 1972)
•Brundtland Commission (1987)
•National Constitutions
•ILO Conventions
•Convention on the Rights of the Child
•ICESCR
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United
Nations
Commission
on Human
Rights
International
Labour
Office
Resolution 1995/81: “a serious
threat to the human rights to life
and health of everyone…”
Special Rapporteurs 2004,
2006: rising e-waste exports
pose an obstacle to realization
of human right to health, “poor,
vulnerable, marginalized suffer
disproportionately from
exposure to toxic chemicals…”
E-waste is the newest and most
threatening form of hazardous
waste.
98% of China’s 700,000 e-waste
recycling jobs are in the informal
sector (Green Jobs for Asia
Conference, 2008).
China receives up to 70% of
global electronics discards.
(UNESCO Future Forum 2009)
E-waste recycling is a growing
employment sector in developing
countries that gravely endangers
human and ecosystem health.
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Is e-waste export (dumping) prohibited under international hazardous waste regulation?
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Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal
(1992):
Minimize generation
Limit international movements
Promote national self-sufficiency
1990-1995 transfers
from OECD countries:
disposal - 31.1%
recycling +32%
Basel Ban Amendment (1995): a complete ban
of all hazardous waste exports for disposal,
recycling and recovery from Annex VII
countries (OECD, EU, Lietchtenstein) to non
Annex VII countries (all other Basel Parties).
• Entry into force of the Basel ban (interpretation of Art. 17(5) of the Convention) disputed: ¾ of the original 82 Parties to the Convention
need to ratify or ¾ of the current 172 Parties?
• Canadian position: “There will be a need for recycling of hazardous wastes today, tomorrow and for many years to come.” (disruptive
effects on hazardous recyclables trade)
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What is considered hazardous waste under the Basel Convention?
Scope
• Annexes I & VIII, unless they do not exhibit an Annex III characteristic (explosive, flammable,
liable to spontaneous combustion, liable to become flammable or
give off flammable gases when in contact with water, oxidizing, poisonous, infectious,
corrosive, toxic or ecotoxic).
• Defined as hazardous under domestic legislation of an exporting, importing or transit country that
is a Party to the Convention.
Restrictions
Art. 4(9): Hazardous wastes are exchanged between territories only:
• when exporting country cannot manage self-sufficiently in an environmental manner
• when wastes in question are required as raw material for recycling or recovery in the State of
import (exception: Annex VII to non-Annex VII)
• under other agreed-upon criteria that do not contravene the objectives of the Convention
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Do e-wastes qualify as hazardous wastes?
Hazardous
Annex VIII:
A1150 Precious metal ash from incineration of
printed circuit boards [...]
A1180 Waste electrical and electronic assemblies
or scrap containing components such as
accumulators and other batteries included on list
A, mercury switches, glass from cathode-ray
tubes and other activated glass and PCBcapacitators, or contaminated with Annex I
constituents (e.g. cadmium, mercury, lead,
polychlorinated biphenyl) to an extent that they
possess any of the characteristics contained in
Annex III (note the related entry on list B B110).
A 2010 Glass waste from cathode ray tubes and
other activated glasses.
Exceptions
Annex IX
B1110 Electrical and electronic assemblies:
• Electrical and electronic assemblies consisting of only
metals or alloys
• Waste electrical and electronic assemblies or scrap not
containing components such as accumulators and other
batteries included on list A, mercury switches, glass
from cathode-ray tubes and other activated glass and
PCB-capacitators, or not contaminated with Annex I
constituents (e.g. cadmium, mercury, lead,
polychlorinated biphenyl) or from which these have
not been removed, to an extent that they do not possess
any of the characteristics contained in Annex III (note
the related entry on list A A1180)
• Electrical and electronic assemblies (including printed circuit
boards, electronic components and wires) destined for reuse,
and not for recycling or final disposal.
*** Footnote 20 ***
“are not considered waste”
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Electronics
(functional & nonfunctional)
Final Disposal
Recycling
Annex VIII with Annex I
constituent and Annex III
characteristic: hazardous
waste
Reuse
Refurbishment
Repair
Upgrading
Exempt
from regulation
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Basel Convention, Annex IX: Re-use exemption
• Extends lifecycle.
• Benefits resource and energy
conservation.
• Bridges digital inequalities by
ensuring developing countries’ access
to IT equipment.
• Repair and refurbishment require
replacement and disposal of nonfunctioning parts.
• Eventual need for recycling and
disposal inevitable.
• No mandatory pre-testing, labeling
or certification requirements.
• Guise for illegal dumping : e.g.
75% Nigeria
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Is the Basel Convention an effective measure to mitigate e-waste pollution?
Annex IX
• Exports for reuse unregulated,
significant source
of pollution, major
regulatory gap.
Internal
weaknesses
• Allows fluctuation
in HW definitions:
precise legal
scope unclear.
• Enforcement
relies on principle
of state
responsibility:
reporting &
tracking
inconsistent,
developing
countries lack
infrastructure,
capacity.
•Compliance
Committee
decisions nonbinding, ngo’s
excluded from
process.
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Basel Ban
• Legally
unenforced.
• Does not regulate
export for re-use.
• Linked to rise in
illegal dumping.
(EU)
• Creates closed
trading group
between Annex VII
countries.
(Exclusive access
to ‘waste product’
market: WTO
compatible?)
• Legal ambiguities:
membership to
Annex VII? Article
11 agreements?
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Why should developing countries not be excluded from the waste recyclables market?
Negative impact on
resource extraction,
increased pressure on
manufacturing
industries.
Revenue alternatives,
social repercussions
unclear.
Hinders transfers of
clean technology,
decreases incentives
for cooperation.
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Does not solve waste
generation issues.
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Basel Convention strategies
Trading
Restrictions
Enhance
capacity
Advance clean
technologies
Build
multistakeholder
partnerships
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COP 8 (2006)
Nairobi Declaration on the
Environmentally Sound Management of
Electrical and Electronic Wastes
Decision VIII/2: Creating Innovative
Solutions
Preamble:
Acknowledges risks of e-waste traffic to
countries that lack capacity.
&
Highlights development opportunities created
through proper recycling and recovery.
Mandates Working Group to monitor global
developments in e-waste management.
Guiding principles:
• e-waste awareness
• transfer of technologies
• green design (phasing out of toxics)
• adoption of product stewardship & producer
responsibility policies
Calls for increased financial support and
practical engagement, development of pilot
projects on environmentally sound collection,
re-use, recycling and refurbishment operations
in developing countries.
Strengthen efforts to combat illegal traffic.
Ensure re-use donations are not end-of-life.
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Green Design
Recast waste
minimization as a
main objective of
industrial production.
Manage waste
phase before
product
materialization.
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Eliminate toxic
characteristics of
products.
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Lifecycle Thinking
View products as sources of environmental problems.
Shared stakeholder responsibility in pollution prevention and control.
Principle of Extended Producer Responsibility (EPR)
Manufacturers and importers take responsibility for the environmental
burdens of a product throughout the entire lifecycle of the product and
not just the phase in which they are directly implicated.
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Implementing EPR
Administrative
• Product takeback schemes
• Re-use and
recovery targets
• Environmental
standards
Economic
• Product taxes
• Advance
disposal fees
Informative
• Marking and
labelling
• Customer
information
• Tradable
recycling credits
R E S P O N S I B I L I T I E S
Financial
Physical
Informational
Liability
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EPR Policies Innovate
Transfer of
waste
management
responsibility to
private sector.
Extend traditional focus
of environmental
intervention from
byproduct to product.
Create
incentives for
industry to move
towards waste
minimization.
E X P E R I M E N T A L !
Environmental and financial impacts are not evident:
Germany - Ordinance on the Avoidance of Packaging
Waste (1991)
EU – EoLV Directive (2000)
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High degree of variation in EPR Policies
Government
intervention
(local/national/none).
Division of
responsibilities
between
stakeholders.
Impacts on international
trading, health and
development of green
technologies.
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Waste Electrical and Electronic
Equipment (WEEE) Directive
(2002)
Hold producers responsible for
recycling/reprocessing/disposal operations related
to EEE listed in Annex 1A:
1: large household appliances
2: small household appliances
3: IT and telecommunications
4: Consumer Equipment
5: Lighting Equipment
6: Electrical and Electronic Tools
7: Toys, Leisure & Sports
8: Medical Devices
9: Monitoring and Controlling
Instruments
10: Automatic Dispensers
Restriction on the Use of Certain Hazardous
Substances in Electrical and Electronic
Equipment (RoHS) Directive (2002)
Design and manufacturing obligations on producers to
phase out use of 6 toxics:
Lead
Mercury
Cadmium
Hexavalent Chromium
Polybrominated biphenyls (PBB)
Polybrominated biphenyl ehters (PBDE)
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WEEE Directive
Producer Definition
Manufacturers, Brand owners, Persons who professionally importer/export into EU
Member State irrespective of selling technique.
Obligations
To provide all end-of-life reuse and treatment information that may be required by
recycling facilities, including disclosure of EEE components, materials and location of
dangerous substances.
To finance collection, recycling, recovery and disposal operations.
Producer Responsibility
End
User
Collection
facility
• New waste (placed on market after
13 Aug. 2005)
• Historical waste
• WEEE from private households
(includes WEEE from industrial,
institutional and other sources of
similar nature and quantity
• WEEE from users other than private
households
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WEEE Directive: Producer Responsibility
New waste
Historical waste
Producers are individually responsible for
financing end-of-life operations related to their
own products.
For WEEE from PH: Producers must provide a
financial guarantee with every new product
placed on the market (i.e. recycling insurance,
blocked bank account, participation in collective
WEE management scheme).
WEEE from PH: Producers existing on the
market (at the time the treatment costs occur)
assume collective responsibility according to
“their respective share of the market by type of
equipment.”
WEEE from users other than PH: Producers are
jointly responsible with users.
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WEEE Directive: Government Role
Set up collection and financing systems where consumers can return WEEE at least free of charge
(Art.5(2)).
Keep a registry of producers (Art. 12(1)).
Collect information on annual quantities put on market, collected, recycled and exported.
Encourage green design (Art.4).
Meet collection target of 4kg per inhabitant (Art.5(5). New proposal revises this to 65% by weight of all
Annex 1A EEE placed on market in 2 preceding years.
Consumer information: Inform and educate users on WEEE health hazards and disposal operations,
facilitate access to collection sites, promote consumer awareness and participation.
PRODUCERS
DISTRIBUTORS
(Article 10, WEEE)
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WEEE Directive Key Implementation Issues
Producer Definition
Collection Responsibilities
When producer is the first
importer into the national
State (wholesaler, distributor,
retailer):
• Producer changes
each time product
crosses national
borders.
• Several producers
held responsible for
same product
(markings, financial
guarantees).
Physical and financial
responsibilities for collection of
WEEE from PH not specifically
allocated to producers. (Deviation
from the PPP).
Individual financial responsibility
with respect to new products not
unanimously transposed
(ambiguous or unaddressed).
Lack of harmonization
Varying national requirements
(form & substance) means
excessive administrative
burden & compliance cost on
producers.
Differentiation in interpretation
of key terms:
‘producer’, ‘WEEE from
private households’, ‘put on
the market’.
Differences in the obligations
of distance sellers & foreign
entities leaves space for free
riders.
Inclusion of wholesalers and
retailers as producers.
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Proposal for a revised WEEE Directive
Harmonized system of producer registration/reporting,
inter-operational national registers.
Clarification on product scope (new categorization
household/non-household)
Minimum standards for inspection & monitoring
requirements for WEEE destined for shipment.
R E G U L AT O R Y
G A P !
• EEE producers’ access to their own WEEE not
guaranteed (leaks outside producer-funded
system).
• Other market actors competing for WEEE remain
unregulated.
• No obligation on consumers to discard through
appropriate channels.
Higher targets for recycling and reuse.
Promotes the extension of producers’ financial
responsibility for WEEE throughout the whole waste
chain, including from private households.
• No obligation on municipalities to transfer all
collected WEEE back to producers for subsequent
treatment.
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Regulations for the Administration of the
Recovery and Disposal of WEEE, Order
No. 551, PRC (2009)
Takes effect January 2011.
Product scope to be defined in forthcoming
catalogue.
Regulates ‘recovery’ (collection), disposal.
Does not cover reconditioning, maintenance,
reuse.
Main objective is to regulate disposing enterprises.
Administrative Measure on the Control
of Pollution Caused by Electronic
Information Products, Order No. 39,
PRC (2006)
Lead
Mercury
Cadmium
Hexavalent Chromium
Polybrominated biphenyls (PBB)
Polybrominated biphenyl ethers (PBDE)
Information disclosure (content levels,
‘environment-friendly use period’, recyclability),
labeling restrictions, pre-market compliance
testing and certification.
Range of products: electronic components but
not assemblies, packaging, raw materials).
Products for export not included.
All actors involved in production, sale, import
must comply.
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How does the China WEEE impact EEE stakeholders?
RECYCLERS
Establishes permit system for
‘disposing enterprises’ (WEEE
recyclers).
Prohibits all other entities and
individuals from engaging in WEEE
treatment.
Obliges all actors involved in WEEE
treatment (recovery, storage, transport,
disposal) to comply with environmental
protection regulation and
environmental hygiene administration,
and to establish WEEE monitoring and
information data management systems.
PRODUCERS
Not obliged financially or otherwise
in WEEE collection. Encouraged to
collect WEEE independently or
through their distributors, repair
organs or other entities.
Responsible for disclosing
information on toxic components and
product recyclability, and contributing
to a government-administered special
fund for WEEE disposal. (Rules
pertaining to collection,
administration and use of the fund
forthcoming).
USERS
Provides an ‘asset write-off’ to gov’t
agencies, social organizations,
enterprises and institutions that
deliver WEEE to disposing
enterprises.
• Fails to provide an accountable,
coherent system for WEEE
collection.
• Does not solve problem of
household e-waste being diverted to
informal sector.
• Fails to provide framework for
consumer awareness / participation in
safe disposal.
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Japan WEEE/RoHS Laws
HARL (2001)
• Establishes manufacturer take-back
schemes for tv’s, refrigerators, washing
machines and air conditioners.
• Consumers pay a recycling fee by
purchasing a recycling ticket at retailers
or post office. Products are returned to
retailers, municipalities.
• Fees are transferred to producers on a
monthly basis. ***Fees are low and
difference in actual recycling cost is
assumed by producers.***
LPEUR (2001)
• Covers consumer-owned IT
equipment, some other products.
• Obliges Japanese manufacturers in
specific industries to incorporate 3 r’s
(reuse, recyle, reduce) in their business
model.
• Imposes a point-of-purchase recycling
fee. Consumer gets a label to put on EoL
equipment, then sends it to post office.
Postal system sends it to appropriate
recycler.
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RoHS (J-MoSS, 2006)
• Same six substances as China, EU.
• Applies to PCs, TVs, refrigerators,
washers, dryers, microwave ovens and
unit air conditioners.
• Does not prohibit use, imposes labeling
restrictions, information duties when
content levels of these substances exceed
the allowable limit.
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United States Approach
California:
Landfill bans & EPR policies in 18 States.
• RoHS law (EWRA, 2003), mandatory
recycling system and export ban (same
standard as Basel Convention).
• Local governments responsible for
collection and handling.
• Industry participation limited to green
design, no financial or other implication in
recycling phase.
46.1% of U.S. population uncovered by e-waste
laws. (Consumers are charged a fee by e-waste
collectors.)
Federal export rules don’t prohibit U.S. recyclers from exporting.
State-level patchwork policies pose administrative and financial burden.
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U.S. Legislative Proposals (May 2009)
Environmental Design of Electrical Equipment
(EDEE) Act
Amendment to the Solid Waste Disposal Act to restrict
certain exports of electronic waste
No electro-industry product will be manufactured
or imported unless it meets m.a.c. limits (same 6
substances as EU RoHS.)
Prohibits e-waste exports to non-OECD countries.
(Does not establish national EPR rules or
guidelines).
Electro-industry product:
Product scope:
"any product or equipment that is directly used to
facilitate the transmission, distribution, or control of
electricity, or that uses electrical power for arc welding,
lighting, signaling protection and communication, or
medical imaging, or electrical motors and generators".
"used personal computers, servers, monitors, televisions,
other video display products, printers, copiers, facsimile
machines, video cassette recorders, digital video disc
players, video game systems, digital audio players,
personal digital assistants, telephones, image scanners,
and other used electronic products the [EPA] determines
to be similar".
Detailed list of exclusions and exemptions (e.g.
electrical wire, cables and accessories, medical
equipment, products with 300V rating, fixed
installations).
IT equipment? Household / consumer
equipment? Toys? Leisure & Sports
equipment?
Exemptions include re-use, repair, refurbishment.
U.S. exporters not obliged to provide contractual
proof of receiving facility’s consent or capacity
to handle the shipment in an environmentally
sound manner.
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Canadian E-waste Regulation
Canadian Council of Ministers of the
Environment (CCME) :
Canada-wide Principles for Electronic
Product Stewardship
Recommended E-Waste Products
EPR/ARF systems
in place:
pending:
Alberta
Ontario
Saskatchewan
Nova Scotia
British Columbia
Manitoba
Quebec
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Canadian Comparison
Quebec
Draft Residual Materials Management Policy (Nov. 2009)
Saskatchewan
Waste Electronics Regulation
Electronic Products:
“electronic appliances used to send, receive, display, store,
record or save information, images, sounds or waves, and
their accessories, except products designed and intended to
be used in an industrial, commercial or institutional
environment exclusively.” (Art. 23)
Designated products:
Computers & peripherals
Printers
Monitors
Televisions
Audiovisual equipment (including in-vehicle)
Non-cellular telephones and answering machines
Subcategories:
Computers & peripherals
Televisions
Printers, Scanners, Faxes, Photocopiers
Phones & devices (cellular, satellite, traditional, pagers,
hands-free)
Video game consoles & peripherals
Players, Recorders, Burners
Digital photo frames, e-books, GPS systems, walkietalkies, digital cameras, camcorders.
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International WEEE/RoHS Legal Landscape
P R O S P E C T I V E
I M P R O V E M E N T S
Information Sharing and
Stakeholder Participation
Responsibilities of NonProducers
Harmonized RoHS Adoption
Lack of stakeholder awareness and
incentive contribute to improper
disposal. Need to strengthen public
education initiatives.
Govt’s need to address the role and
financial interest of e-waste
brokers, recyclers and other nonproducers involved in WEEE
chain.
Essential dimension of e-waste
governance.
Interlock interests of
manufacturers, consumers,
recyclers and the informal sector.
Developing countries: Inclusion of
informal sector in environmental
management necessary (e.g.
utilizing their collection/handling
skills).
Important that producers can
access WEEE before it enters
unregulated recycling channels.
Greater transparency and
corporate responsibility needed in
the recycling sector.
No action on RoHS will hurt
domestic industries, slow down
global standardization of green
design and clean production.
Discordance between policies
poses serious compliance issues,
costs (especially for SME’s, Asian
contractors).
Need for financial and technical
assistance to EEE supply chain
actors.
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Sustainable
Consumption
Sustainable Production
E- Waste management
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An environmental
framework for
electronics
consumption?
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T H A N K
Y O U
Sabaa Khan
[email protected]
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Sustainability, CERIUM 2010