E-Waste Product Stewardship – New Zealand

• Although Kiwis are among the highest consumers of e-products globally, these trends are not unique to Aotearoa and there are a range of product stewardship schemes and extended producer responsibility programmes that we can learn from.
• Europe has established an extended producer responsibility framework through the European Waste Electrical and Electronic Equipment (WEEE) Directive, which covers all e-products; excluding batteries which have their own Directive.
• The WEEE Directive was introduced in 2003, has undergone multiple reviews and updates and provides a good benchmark as a starting point for New Zealand’s regulated e-product stewardship investigations.
• TechCollect NZ is a member of a global e-product PSO (Product Stewardship Organisation) network (through the WEEE Forum – represented in the CEN) and has held a series of workshops with international e-product PSOs to understand what has worked well in other jurisdictions, what hasn’t, what we should avoid in Aotearoa, and what scheme design elements are essential to spur more circular stewardship of e-products across their lifecycle; for all stakeholder groups.
• TechCollect NZ has also undertaken research to assess international e-product stewardship approaches and will produce a research paper that will be published and made publicly available.

• E-product treatment costs vary across different e-product categories and streams – these costs depend on a number of factors including (but not limited to), the value of recoverable resources embedded within e-products, the capability of our local recycling sector to manage different e-products and components, and offshore export and processing requirements for any products, components or materials that we cannot manage in Aotearoa.
• TechCollect NZ is engaging broadly across Aotearoa’s e-product management sector to understand business-as-usual (BAU) recycling costs and ongoing recommendations for a regulatory e-product stewardship scheme in New Zealand.
• Regular review of scheme treatment costs will be required to ensure that the recommended scheme funding structure is updated to reflect ongoing changes and fluctuations to local and international commodity trading markets for recovered resources.
• We want to avoid a ’race to the bottom‘ at all costs and will put forward recommendations to ensure this does not take place in New Zealand whilst ensuring recycling activities are carried out to achieve defined objectives under the scheme and meet appropriate treatment standards.

‘E-waste’ can be described simply as any device that requires a plug or battery to operate (including batteries themselves), and includes:

1. 1. re-chargeable and non-rechargeable batteries, including lead-acid batteries used in vehicles or stationary power systems (excluding large batteries used in electric vehicles and energy storage applications); and
   2. categories of waste electrical and electronic equipment (WEEE) defined in Annex III and IV of European WEEE Directive 2012/19/EU.

In the WEEE Directive, electrical and electronic equipment (EEE) is defined as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer, and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current and 1 500 volts for direct current. This definition extends to all EEE components, sub-assemblies, and consumables which are part of the product at the time of discarding e.g. printer cartridges.

Please note, the WEEE Directive currently exempts the following EEE arisings from extended producer responsibility requirements:

• arms, munitions, and war material intended for specifically military purposes
• equipment designed to be sent into space
• large-scale stationary industrial tools
• medical devices where such devices are expected to be infective before end of life, and active implantable medical device

See the Declaration of Priority Products Notice 2020 here: Corrigendum—Declaration of Priority Products Notice 2020 – 2020-go4533 – New Zealand Gazette

See the categories of waste electrical and electronic equipment (WEEE) defined in Annex III and IV of European WEEE Directive 2012/19/EU here: EUR-Lex – 32012L0019 – EN – EUR-Lex (europa.eu)

• TechCollect NZ is a member-based, New Zealand not-for-profit organisation.
• We don’t own trucks, collection equipment, or undertake any e-product/e-waste management or treatment activities ourselves. We work with local service providers in the New Zealand market who deliver services in line with our high standards of operation.
• TechCollect NZ has appointed an independent consultant to lead the Circular E-Stewards Network (CEN) working group and stakeholder engagement activities to provide an impartial voice to steer the co-design process. TechCollect NZ is one voice at the table.
• Also, as part of our investigations, the CEN will be assessing a range of potential Product Stewardship Organisation (PSO) models to test the pros and cons of each option for the Ministry for the Environment (MfE) to assess and consider in the next stage of consultation and analysis post co-design.
• The objective of our co-design project is to recommend a preferred product stewardship model to the New Zealand Government and inform cost-benefit analysis and further consultation before drafting any legislation.

• TechCollect NZ will work with a range of collection partners to see how we can provide e-waste services for all e-waste in different regions across New Zealand.
• Other products not covered by our programme i.e. non-ICT equipment, will require additional funding and we will be exploring the most cost-effective options across the country to ensure our partners can support their communities with safe and responsible recovery and treatment pathways.
• When it comes to batteries, we will be investigating suitable product stewardship options for small handheld batteries in New Zealand, while the Battery Industry Group are tasked with developing product stewardship recommendations for large batteries – please use this link to learn more about the Battery Industry Group and their circular product stewardship approach for large batteries.

• There are currently several voluntary product stewardship programmes for e-products operating in New Zealand, and while these programmes go a long way to address negative product lifecycle impacts and improve waste reduction, product reuse, recycling and resource recirculation, they do not operate on a level playing field or cover all e-product categories with full market participation.
• The CEN is engaging directly with these programme operators to understand their scheme design preferences under a regulated system and how these programmes could continue to operate going forward – this includes understanding options for Individual Producer Responsibility (IPR) approaches that would meet the recommended scheme objectives and performance measures.
• Some of these voluntary product stewardship programmes include Fuji Xerox’s Zero Landfill Scheme, the RE:mobile programme and Sharp’s Recycling and Waste Reduction Scheme.
• These scheme operators and the stakeholders supporting these initiatives should be applauded for their early and proactive work in product stewardship and we want to work closely with them to learn what has worked well for their programmes and understand what could be improved under a regulated scheme.

• After the recommendations report has been delivered to MfE, there will be a detailed regulatory and economic impact analysis of the scheme design options recommended and further stakeholder consultation (likely to include public consultation).
• This subsequent analysis and further consultation will be led or commissioned by Government and any proposed regulations will be presented to Cabinet for decision.
• An application for e-product scheme accreditation is expected within one year from when the recommendations report is delivered.
• See the General Guidelines for Product Stewardship Schemes for Priority Products Notice 2020 (including expected timing – item 3) here.

• In Australia for example, the cost of a regulated e-waste scheme is estimated to be between $1.55 and $1.85 for an e-waste unit size equivalent product of 0.75 kilograms.
• This means that for less than a cup of coffee, we can make sure that e-waste is managed responsibly and in a way where valuable materials are recovered and retained for the benefit of local supply chains.
• The reality is that recycling costs change across different products depending on a number of factors (as above). TechCollect NZ will explore these elements in detail throughout the co-design process; leading to fit-for-purpose recommendations in the New Zealand context.

• TechCollect NZ supports sensible product stewardship interventions that align with New Zealand’s waste management hierarchy i.e. reuse before recycling wherever possible, and those that place a heightened focus around waste avoidance.
• The CEN will be exploring what role reuse initiatives can play in a regulatory product stewardship scheme.
• Product repair and reuse provides a number of benefits within the interest of national supply chains, such as retaining valuable resources locally and creating local skill-based jobs. This will also be a key driver in propelling a more circular and lower-carbon economy in Aotearoa.

• With more e-products being recovered in Aotearoa to be managed through formal recycling channels, TechCollect NZ expect to see a regulated product stewardship scheme significantly contribute to the creation of local skill-based employment opportunities.
• This extends to e-product collection, sorting, transport, repair, refurbishment and recycling activities; leading to local jobs for Kiwis in our e-product and resource management sectors.
• In Australia, the Australian Council of Recyclers has estimated that for every 10,000 tonnes of waste recycled, approximately 9.2 full time jobs are created. For the same amount of waste managed in landfill, only 2.8 full time jobs are created.