E-Product Stewardship – Aotearoa New Zealand

• Although Kiwis are among the highest consumers of e-products globally, these trends are not unique to NZ and there are many international schemes we can learn from.
• TechCollect NZ led targeted research and consultation to understand technical aspects of different scheme design approaches offshore and gather insights to co-develop interventions recommended for an NZ scheme – see the International Research Paper: Product stewardship and extended producer responsibility for e-products and e-waste, for more information.
• TechCollect NZ is also a member of the WEEE Forum – a not-for-profit association of 50 product stewardship organisations (PSOs) exchanging reputable knowledge, experience and best practice to tackle the e-waste challenge globally.

• The key elements of scheme design and how they can support the scheme’s operation are represented as Scheme Design Elements (SDEs).
• The 12 SDEs are central for defining what the scheme could look like and how it would function and includes 1) Scheme framing, 2) Scheme product scope, 3) Targets and data, 4) Liable party determination, 5) Fee structure, 6) Mandatory standards, 7) Governance structure, 8) Compliance and monitoring, 9) Education and Awareness, 10) Accredited scheme manager roles and responsibilities, 11) Regulation, and 12) Scheme stakeholder roles and responsibilities.
• The SDE recommendations have been informed by targeted local and international research, robust consultation, and detailed feedback from the Circular E-Stewards Network and wider stakeholders.

• A ‘circular economy’ is an alternative to the traditional ‘linear economy’ in which resources are kept in use for as long as possible, extracting the maximum value from them while in use, and then recovering and regenerating products and materials at the end of each service life.
• In a linear economy, we take resources, make new products and throw them away when they are no longer wanted.
• In a circular economy, we make new products to be more durable, repairable and recyclable, recover and reuse them (as much as possible), and make the most out of the valuable and finite resources already in circulation. We rethink the way products are designed, the materials we are selecting for their construction, and look to replicate the regenerative systems in nature.
• The Ellen MacArthur Foundation state that “the circular economy can address up to 45% of all greenhouse gas emissions globally – and countries are starting to incorporate circular considerations into their climate action plans.”

• ‘E-product’ stands for ‘electrical and electronic product’ and can be simply described as any device that requires a plug or battery to operate (including batteries themselves).
• ‘E-waste’ (aka ‘WEEE’ – waste electrical and electronic equipment) is a term used to describe any e-product that is unwanted or has reached the end of its useful life.
• The New Zealand Government’s Declaration of Priority Products Notice 2020 for e-products and e-waste covers all:
  1. rechargeable batteries designed for use in electric or hybrid electric vehicles or household-scale and industrial renewable energy power systems, including but not limited to, lithium-ion batteries,
  2. 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
  3. categories of waste electrical and electronic equipment (WEEE) defined in Annex III and IV of European WEEE Directive 2012/19/EU.
• Note: The Battery Industry Group (B.I.G.) has developed regulated product stewardship scheme recommendations for rechargeable batteries designed for use in electric or hybrid electric vehicles or household-scale and industrial renewable energy power systems. All re-chargeable and non-rechargeable batteries are included in the e-product stewardship co-design process led by TechCollect NZ.
• See the Declaration of Priority Products Notice 2020 here.
• See the categories of waste electrical and electronic equipment (WEEE) defined in Annex III and IV of European WEEE Directive 2012/19/EU here.

• The word ‘stewardship’ means to take care of something, and the term ‘product stewardship’ is a principle for equitably sharing responsibility to address negative product impacts – this principle spans across a product’s entire life cycle and value chain, all the way from manufacturing to end-of-life management and material recirculation.
• Product stewardship activity seeks to coordinate fit-for-purpose interventions to address negative impacts and market failures across a product’s life cycle and value chain with everyone who can and should make a difference.

• Under NZ’s recommended e-product stewardship scheme structure, there are different options proposed for voluntary programmes to continue providing these much-needed services and form part of scheme operations – this includes recommendations enabling the accredited scheme manager to work with other Product Stewardship Organisations (PSOs) under an umbrella model for certain e-product categories, and via Individual Producer Responsibility (IPR) programmes typically managed or contracted by e-product manufactures, importers or distributors.
• There are several voluntary e-product and e-waste stewardship programmes operating in NZ at present, and while these programmes go a long way to address negative life cycle impacts and improve waste reduction, e-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 voluntary programme operators and stakeholders supporting these initiatives should be applauded for their early and proactive work in NZ’s e-product stewardship space, and TechCollect NZ thanks them for sharing their valuable views and experience throughout the co-design process.

• That will depend on where you sit within the e-product/e-waste value chain and the scheme services you would either seek to access or provide.
• Refer to Table 7 – Stakeholder definitions and roles and responsibilities, in Appendix A of Report Two (Scheme Framing and Design Recommendations) for a detailed overview by scheme stakeholder/participant group to see where you sit, and the corresponding roles and responsibilities recommended.

The next steps* following co-design and progressing towards scheme implementation include:

1. Public consultation on supporting regulations – The final report recommends that regulations are needed to support the regulated e-product stewardship scheme. This work is undertaken by the Ministry for the Environment and will include a public consultation process and government approval.
2. Apply for scheme accreditation – A potential scheme manager applies for accreditation by submitting the priority product stewardship application form. The application is assessed and if the Minister for the Environment is satisfied the scheme meets the requirements of the Waste Minimisation Act 2008, it will be accredited.
3. Scheme implementation – The earliest possible in-effect start date for the scheme is expected to be in 2025.

*These steps may or may not take place in sequential order e.g., an application for scheme accreditation may be submitted or accredited prior to public consultation on supporting regulations.

See the General Guidelines for Product Stewardship Schemes for Priority Products Notice 2020 (including expected timing – item 3) here.

• TechCollect NZ is a member-based, not-for-profit organisation established by leading global technology companies committed to supporting the development of a fair and effective regulated e-product stewardship scheme in NZ.
• TechCollect NZ deliver national member programmes and a free country-wide collection and recycling service for ICT equipment, partnering with local service providers who meet stringent health, safety and environmental standards.
• TechCollect NZ and our members are big believers in the benefits of fit-for-purpose product stewardship, especially for products and materials that pose a real threat to our environment and the well-being of those managing these products throughout their life cycle, such as e-products.
• With the right mix of experience, expertise and industry support, the co-design process led by TechCollect NZ and co-funded by TechCollect NZ’s members and a Waste Minimisation Fund grant.
• TechCollect NZ’s members are committed to implementing a regulated e-product stewardship in NZ as soon as possible and TechCollect NZ is now preparing for an application to seek accreditation as NZ’s scheme manager.

• One of the overarching objectives recommended for the scheme’s framing is to prioritise life cycle management interventions from the top of the waste hierarchy i.e., reuse before recycling wherever possible, and those that place a heightened focus around waste avoidance.
• To make and track progress in this area, the accredited scheme manager is proposed to work with all scheme service providers and encourage e-product diversion from scheme recycling channels for reuse and/or repair wherever possible, and report scheme diversion performance annually – this will help to create market drivers and financial incentives for scheme participants to extend e-product life cycles as much as possible.
• The recommended scheme framing is centered around circular economy principles where e-product reuse, recovery, and end-of-life management considerations are integrated at the design stage with the aim of improving the environmental performance of e-products throughout the entire life cycle.
• Acknowledging that different e-product categories are further along in terms of repairability, reusability, and recyclability than others, the recommended staggered scheme implementation framing option splits a circular economy setting into three ‘threads of circularity’ – i.e., recovery and recycling, repair and reuse, and product design – and has a primary and secondary focus for each e-product category over the scheme’s short-, medium-, and long-term timeframes across these three threads.
• The progression of each e-product category through the three timeframes, and respective primary and secondary focus areas, is recommended to occur based on each e-product category’s ability to:
  • meet the primary focus objectives of the current timeframe; and
  • be assessed as sufficiently mature in respect to recyclability, repairability, or product design to move to the next timeframe.
• For example, in the scheme’s short-term where recovery and recycling is the primary focus for a given e-product category, and if this is working as it should and suitably qualified repair agents are widely available, the e-product category will be assessed as sufficiently mature with respect to recovery and recycling and will shift to the scheme’s medium-term timeframe where reuse and repair becomes the primary focus, with a secondary focus on product design interventions.
• E-product repair and reuse initiatives provide a number of benefits within the interest of national supply chains, such as retaining valuable resources locally and creating local skill-based jobs.
• To further support e-product repair, reuse and life cycle extension activity as part of scheme operations, it is recommended that the New Zealand Government provide ongoing grant funding support for vocational training in NZ’s e-product repair and refurbishment sectors – to ensure a sufficient number of local repair technicians are available to enable the expansion of e-product repair and reuse focus for all e-product categories under the scheme as soon as possible.

• There are different service costs and fee considerations across individual e-product categories – this speaks to the varying sizes, characteristics, material composition, management pathways and available service options for the broad scope of e-products that fall under each category.
• Scheme services that will require funding include e-product and e-waste collection, sorting, storage, transportation and recycling activities. Scheme fees will also be raised to cover scheme administration costs e.g., scheme management and reporting, education and awareness raising etc.
• Of the fee structures investigated during the co-design process, an Advanced Stewardship Fee (ASF) is recommended, whereby a predetermined fee (yet to be determined) is applied to all in-scope e-product categories that manufacturers, importers and distributors place on the NZ market for sale to Kiwi consumers.
• How scheme costs would either be internalised or passed onto Kiwi consumers (in part or in full) will be for individual liable parties with financial obligations to determine i.e., in-scope e-product category manufacturers, importers and distributors.
• As the ASFs would be set by regulation under s23 of the Waste Minimisation Act 2008 and would therefore be published in advance, consumers will have a clear understanding of scheme costs (which are expected to vary by e-product category on a per kilogram basis).
• The reality is that scheme costs change across different e-products depending on a number of factors and not all liable parties will follow the same approach.
• In Australia for example, the cost of operating their National Television and Computer Recycling Scheme (NTCRS) is estimated to be between AUD $1.95 and AUD $2.30 per kilogram – This means that for less than a cup of coffee (depending on e-product weight and where you get your coffee), we can support a system where our e-products are managed responsibly, and in a way where valuable materials are recovered and reused to benefit local supply chains.

• With more e-products being recovered in NZ to be managed through formal scheme channels (and not in landfill or worse), TechCollect NZ expect to see a regulated e-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.
• The recommended scheme design will also address some of the major barriers hindering more circular management of e-products right now, including (but not limited to) the costs of responsible management, and the convenience of accessing the best life cycle management services.