Australia’s nationwide scheme for collecting and recycling end of life televisions and computer equipment was conceived with a broader purpose beyond offering a free recycling service to the community. Core requirements include ensuring that the recycling process maximises material recovery and is carried out safely and responsibly. These requirements not only encourage the best environmental outcomes but also safeguard the health and well-being of workers involved in the process. Certification to recycling standards helps to achieve these requirements and plays a pivotal role in fostering public trust in the recycling sector.
What role do standards play, and which ones are e-waste recyclers required to adhere to?
Standards aim to set minimum requirements and a consistent approach to procedures that can be applied across multiple jurisdictions (e.g. can be used in all states and territories in Australia).
The standard for e-waste recycling under the National Television and Computer Recycling Scheme (NTCRS) is AS/NZS 5377:2022. This standard covers activities including collection of e-waste from drop off points, transport, storage, recycling and downstream processing. The standard outlines both the minimum requirements and the guiding principles for achieving safe and environmentally sound recycling practices including maximising and calculating material recovery and managing and tracing separated substances and components.
The value of standards and the performance of the NTCRS to date
Standards play a valuable role in setting the minimum requirements and serve as a reliable benchmark for industry participants. However, for them to be effective, consistent adherence is essential, particularly when enforced within a regulated system like the NTCRS. Otherwise, the value of standards diminishes or may even be lost entirely.
This concern is frequently voiced by various stakeholders familiar with the NTCRS. They express worry about the prevalence of non-compliant recycling practices, encompassing safety, environmental, and commercial issues, which are often attributed to inadequate enforcement of NTCRS Rules as well as state and territory environment protection and work health and safety regulations, in particular those regulating recyclers. Consequently, at times e-waste managed through the NTCRS has been recycled using poor practices and low standards, driven by cost cutting and lack of concern for outcomes. As a result, public trust in the NTCRS can be eroded, and at times has resulted in brand damage to stakeholders involved including the government, co-regulatory arrangements and even e-waste recyclers. It has created an uneven playing field whereby those who use sound recycling standards have higher recycling costs compared to those who are non-compliant.
This issue was also noted by the Australian Council of Recycling (ACOR), in its “Recyclers in Product Stewardship” report who observed that “Too often, cost reduction is prioritised over quality recycling outcomes in such schemes. Not only does this undermine legitimate recycling operations, but it also erodes community confidence in recycling when the system fails”.
How do we drive better outcomes?
With the Federal Government currently looking to expand and improve the national e-stewardship scheme the time is right provide some focus on the issue of recycling and the need and opportunity to improve standards and their enforcement. It is imperative that going forward, mechanisms are put in place to ensure compliance standards are robustly enforced and universally applied across all scheme participants.
The costs of this should be borne directly and equitably by industry. This will allow healthy and fair competition on a level playing field that will foster improvement rather than an unproductive race to the bottom. ACOR’s comment that “Ensuring compliance with existing regulations must be a priority to increase recycling rates” is consistent with the views of the Australia and New Zealand Recycling Platform.
We should also recognise that there is always room to go above and beyond the requirements set in the standards and that we should always be looking to strive for continual improvement. An example of this is the proposed expansion of the NTCRS requiring industry to encourage maximising the re-use of products. This represents a departure from the existing regime, which to date has focused purely on end-of-life management. With this proposed change consideration could be given to the adoption of the R2 Standard. The R2 Standard is globally recognized and aims to institute best practices for the safe, secure and sustainable re-use and recycling of electronics. This includes looking at e-waste through a “Hierarchy of Responsible Management” lens meaning there is a focus on re-use before other options. The R2 Standard is more rigorous than other standards in terms of the due diligence applied to auditing downstream vendors, examining the fate of where materials end up and data security and sensitization.
In a smart circular economy, we should look at ways whereby those achieving the best outcomes gain a competitive advantage by doing so (rather than be penalised). In re-designing the e-stewardship scheme we should look at providing incentives for practices and outcomes that deliver the desired results.