Draft National E-Waste Stewardship Strategy: too good to waste

By Claire Smith, Alice Brennan and Maisie McFadyen
03 Feb 2022
Electrical and electronic products in the telecommunication industry, particularly modems and routers, are the focus of a new discussion paper on e-waste.

Related Knowledge

The Federal Government has released a draft National E-Waste Stewardship Strategy discussion paper, with the aim of reprocessing every end-of-life ("EOL") electronic devices in order to recover valuable materials, and reduce carbon emissions. This is consistent with the targets set in the National Waste Policy Action Plan, and aims to address Australia's rising e-waste levels. This presents opportunities for e-waste recyclers, designers, manufacturers, importers and distributors who have available infrastructure to sort, process and remanufacture e-waste materials. 

Background to the proposed e-waste stewardship strategy

E-waste is the single fastest growing waste stream globally, and in Australia it is expected to rise by nearly 30% from 521,000 tonnes in 2019, to 674,000 tonnes in 2030. This waste is often toxic, making it harmful to both the human and ecological environment, and leads to large greenhouse gas emissions. E-stewardship involves practices that improve the environmentally sound management of electrical and electronic products throughout their life.

Only 50% of Australia's e-waste was collected for recycling in 2019, and only 19% of the material value was recovered ($145 million out of $820 million). This is of particular concern when considering categories such as solar PV panels and storage batteries. This product category's waste is expected to increase 18-fold by 2030, making up 9% of total e-waste. Currently, 84% of solar panels are sent to landfill at their EOL.

E-waste has been described as an "urban mine" of valuable recyclable materials which are often lost when landfilled. This drives up the rate of resource extraction, reduces environmental capital and raises problems of intergenerational inequity. Product stewardship is therefore a fundamental way for the Australian Government and Australian businesses to help manage EOL electrical and electronic products.

Currently, the National Television and Computer Recycling Scheme offers households and businesses free access to industry-funded collection and recycling services for TV's and computers. Voluntary schemes have also been developed and funded through industry associations such as MobileMuster (the collection of mobile phones) and FluoroCycle (for the collection of mercury lights). The Federal Government is supporting the acceleration of industry-led recycling schemes for batteries and other e-products through the National Product Stewardship Investment Fund.

The Minister for the Environment has now targeted electrical and electronic products in the telecommunication industry, particularly modems and routers, in this discussion paper. The Minister has also encouraged the telecommunications industry to demonstrate measurable product design improvements to increase durability, repairability, reusability and/or recyclability. Here lies the opportunity for businesses who have capacity to assist in or complete these processes.

E-Stewardship in Australia

The discussion paper identifies a number of categories of waste, as well as the opportunities and challenges in each respective category. The report also highlights key issues which arose in roundtables with stakeholders, including:

  • Compliance, particularly the challenges associated with meeting government requirements across jurisdictions, and non-compliance generally.
  • Design and manufacture choices which influence EOL options for all electronic products.
  • Landfill bans, and the need to introduce complementary measures when enforcing landfill bans to provide affordable and convenient access to collection and recycling for consumers (both households and business). This is particularly relevant to e-waste given that Victoria and South Australia have banned e-waste from landfills, with Western Australia to do the same by 2024.
  • Product labelling, including consumer labelling and EOL labelling, to address information gaps within supply chains and ensure long-term products still have this information available at EOL.
  • Waste to energy, an emerging technology which treats waste at extremely high temperatures and provides an alternative to landfill for waste that cannot be recycled. This technology can also generate electricity and heating.

The paper asks discussion questions on each of these topics that interested parties can choose to address in their submissions.

Two E-Waste scenarios

The discussion paper is accompanied by an expert report which examined two potential e-product strategies to reduce e-waste in Australia and models the 2030 impacts of each strategy. Both strategies would require policy changes and investment in order to succeed. The report emphasised that the scenarios are not mutually exclusive, and could co-exist to achieve optimal results.

  1. Increase recycling of e-waste to 80%, and increase high efficiency recycling systems:

    The first scenario looks at the effect of increasing recycling to 80%, as well as increasing the level of high-efficiency recycling systems. In this case, it is predicted that e-waste recycling rates would increase from 54% to 80% from 2019 to 2030, in line with the National Waste Policy Action Plan targets. To achieve this, high efficiency recycling processes (where e-waste is dismantled for full material recovery) would need to become the predominant method of recycling. Low efficiency recycling (where items are shredded) would continue, however it will only represent 30% of the recycling taking place.

    Under this scenario, 380,000 tonnes of waste would be sent to high-efficiency recycling processes, 160,000 tonnes to low-efficiency recycling processes, and 128,000 tonnes to landfill. This is an additional 140,000 tonnes of material being recycled, and more than 340,000 additional tonnes of e-waste being dismantled for high value recycling. The value of materials recovered from this process would increase almost four-fold, from $160 million to $600 million.

    Boosting recycling to 80% and increasing high-efficiency recycling systems would significantly increase the supply of secondary commodities, replacing the need to extract and produce primary commodities. High-efficiency recycling would also create more local jobs, with individuals required for product dismantling.

    This scenario avoids approximately 2.7 million tonnes of CO2 by 2030 through improved recycling processes.

  2. Extend e-product life spans by 10%
  3. The second scenario considers the effect of increasing the lifespan of all products by 10%, starting in 2021. This would reduce e-product failures, resulting in a direct avoidance of e-waste produced. Under this model, 12% less products would be introduced to the market, resulting in 9% less e-waste arising, effectively avoiding 60,000 tonnes of waste.

    This has the most significant impact on the solar PV and battery storage product category. The increased lifespan results in a 19% reduction in annual consumption.

    The expert report has noted that this strategy would have an economic impact, and would influence local job opportunities, due to the reduction in consumption of new products. It is noted that this would be partially offset by the increase in reuse, repair and refurbishing activities that are required to keep goods running for longer. There is even a suggestion that this scenario would create more local jobs, given that new products are often manufactured overseas.

    Extending the lifespan of products by 10% is projected to save 1.2 million tonnes of CO2.

What do these scenarios mean for the waste industry?

The expert report notes that there will be four main opportunities to arise from these scenarios:

  1. consumer and industry interest in "right to repair" is high. This could prompt new "repair café's" being developed, thus generating local jobs and reducing greenhouse emissions;
  2. refurbishing and remanufacturing creates local jobs and keeps products and materials at higher environmental and economic value than recycling;
  3. recycling activities create local jobs and generate recycled material for manufacturing in Australia. In 2019, 58,000 tonnes of e-waste were processed in high efficiency recycling systems, and 222,000 tonnes were shredded to recover metals. Materials worth $145 million were captured; and
  4. the materials in e-waste in 2019 were worth $820 million - particularly in solar panels which contain copper, silver and silicon. These can be remanufactured to be used in electric vehicle batteries.

In addition to these, any business that can provide sorting, processing and remanufacturing services will be well situated to benefit from the proposed development. This ranges from manufacturers (who can alter product composition and labelling), marketers (who can influence consumer decisions), and even accountants (who can make sustainable material choices).

Submissions on the draft discussion paper close at 5pm, Friday 25 February 2022.

Get in touch

Clayton Utz communications are intended to provide commentary and general information. They should not be relied upon as legal advice. Formal legal advice should be sought in particular transactions or on matters of interest arising from this communication. Persons listed may not be admitted in all States and Territories.