Tracey Rawling Church, Head of CSR at KYOCERA Document Solutions UK and a regular contributor to seminars and conferences on sustainability, CSR and the circular economy, assesses new EU proposals for waste management and recycling.
The new EU Circular Economy Package, announced on December 2, was hotly anticipated by TechUK and other industry bodies. When the previous plan was withdrawn, the initial dismay was tempered by the EU’s claim that the new plan would be more ambitious. While there are still some details to be ironed out, it certainly takes a more holistic approach to creating circular material flows and improving materials efficiency, particularly for energy-related products.
Some highlights include:
– Increased focus on better product design. The Ecodesign working plan for 2015-17 is to include measures to promote durability, upgradability, reparability and recyclability, and to discourage planned obsolescence. There is mention of Green Public Procurement rules being adapted to reflect this. Economic incentives for better product design are also mentioned, as part of extended producer responsibility schemes, but how this would be implemented is so far unclear. Manufacturers like KYOCERA who already design for disassembly, reparability and durability will be hoping that their investment begins to pay off.
– Recognition of reuse. Products prepared for reuse will in future count towards recycling targets. This is a good thing in principle, but there are fears that this may have the unintended consequence of making products destined for reuse subject to waste handling regulations, adding cost and complexity.
– Preserving material quality. This has been a significant flaw in the current WEEE compliance system. With targets focused exclusively on volume of material collected, there is no incentive to preserve material quality and retain economic value. The new package talks of development of quality standards for secondary raw materials and the introduction of economic instruments to incentivise application of the waste hierarchy, as well as better exchange of information between manufacturers and recyclers on material flaws and impacts. It’s difficult to see how this can be achieved under the current producer compliance schemes, which typically pool waste of myriad types and take a ‘one size fits all’ approach to recycling them.
– Investment in innovation. A €650 million fund will be established as part of the Horizon 2020 project to support innovative projects that promote the objectives of the Circular Economy, including identifying and addressing potential regulatory obstacles for innovators – an opportunity for progressive companies.
– Standards and definitions. There are vague commitments to work with stakeholders to make green claims more trustworthy and improve enforcement of the rules. We can also expect work on the Product Environmental Footprinting programme to accelerate. This already has a strong focus on electronics.
Devil in the detail
The devil, as always, will be in the detail.
The Netherlands, which sees itself as a leader in Circular Economy innovation, is taking over the EU Presidency for the first half of 2016, and there will be pressure to have the package signed off while it is at the helm. Meanwhile, many producers are still getting to grips with the challenge of ‘dual use’ reporting, and work continues to determine the best way to manage the transition from 10 to six categories to comply with WEEE open scope.
Electrical and electronic products have always been a priority sector for the EU’s Circular Economy strategy, not least because of the critical raw materials that electrical and electronic products contain. But the Circular Economy package includes no new legislative proposals, only tweaks to existing rules and non-legislative initiatives.
Although we can expect work on implementing the package to move ahead swiftly, it will take longer for the waste legislative elements to filter through. Future legislation on energy-related product design will also be influenced by the outcome of COP21, which seems to indicate an increased level of ambition on curbing emissions.
Whether these changes will be beneficial or detrimental to the tech industry in the long-term remains unclear. On the one hand, we have moves to make producers liable for collection costs, as well as treatment and recycling costs. Balanced against that are plans for variable financial contributions from producers to reflect end-of-life recycling and treatment costs. While it’s clearly preferable from a sustainability point of view to have efficient materials cycles and to recover high value, high quality recyclate, all these systems and processes are likely to add cost, which manufacturers and their channel partners will be under pressure to absorb.