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Closing the product loop

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					Closing the product loop


How Europe is grappling with waste
                Beverley Thorpe
                www.cleanproduction.org
Moving from waste to product focus
– some general themes
   From Waste management to Product
   life cycle
   From Community-funded recycling to
   producer responsibility for end of life
   products




                 Clean Production Action
We are better at making waste than
products
   For every 100 pounds of product
   manufactured in the USA, we create at
   least 3,200 pounds of waste.
   Only 6% of the materials we extract
   each year from the Earth becomes
   durable goods, the other 94% is
   converted into waste within a few
   months
          – Ref: P Hawken

                  Clean Production Action
Previous waste prevention does not
define WHO is responsible




               Clean Production Action
Products need to be considered in their life cycle –
current production is linear and generates
hazardous wastes with fast consumption




                        Clean Production Action
Clean Production cycle is different
to current linear production systems




                Clean Production Action
What Is Clean Production?
   It promotes renewable energy, non
   toxic materials in a closed loop and
   sustainable product design
   It is rooted within circular concepts of
   the product life cycle
   It is based on the Precautionary
   Principle

                  Clean Production Action
UNEP Cleaner Production (CP)
Definition (1990)
                                For PRODUCTION
                                PROCESSES Cleaner
                                Production includes:

                                conserving raw materials
                                and energy;
                                eliminating toxic raw
                                materials
                                reducing the quantity and
                                toxicity of all emissions and
                                wastes before they leave a
                                process
              Clean Production Action
UNEP CP Definition
  For PRODUCTS ….

  the strategy focuses on reducing impacts along the
  entire life cycle of the product….from raw material
  extraction to the ultimate disposal of the product


  Visit www.unepie.org/ for information
  on their case studies and reports.
                     Clean Production Action
Extended Producer Responsibility
(EPR) is one strategy to push CP
   It is a product policy; not a waste policy
   It enacts the „polluter pays principle‟
   and attempts to internalize true cost
   into the product price
   It makes the producer financially and/or
   physically responsible for all stages of a
   product‟s life cycle, including end of life

                  Clean Production Action
Clean Production Action
EPR promotes better design
   EPR can lead to innovation in the design of
   products and product systems by making:
 “the business opportunities connected to re-
   manufacturing and product/service
   approaches more visual and comprehensible
   to the industrial entrepreneurs.”
            – Thomas Lindhqvist, who coined the phrase EPR, 1991

   More recycling and reuse can mean less
   hazardous material use
                     Clean Production Action
Clean Production Action
Why make the producer responsible?
   Only the product designer can choose
   material and form/function of the
   product
   EPR puts the feedback loop back on the
   producer to design for disassembly,
   reuse, and safer recycling
   Hazardous materials increase the
   producer‟s liability and costs

                Clean Production Action
EPR can make products more
recyclable and less wasteful if:
   Focus is specifically on waste from end
   of life products
   Financial responsibility is clear to
   producers for collection, transport and
   recycling
   Meangful targets are established for
   collection and recycling….

                 Clean Production Action
…EPR programs are effective if:
   Recycling is clearly differentiated from
   waste to energy conversion/incineration
   Reporting requirements and
   enforcement mechanisms established
   Producers have incentive to design for
   reuse/recycling
   Consumers have incentives to return
   their old products (eg free and easy)
                 Clean Production Action
EPR is embodied in:
   Bottle return/refund programs
   Product leasing where manufacturer
   maintains control of product
   ownership/reuse/repair eg Xerox
   Providing a Service instead of a
   product, eg Interface supplying floor
   covering service and carpet tile
   replacement versus new carpet

                 Clean Production Action
    First EPR program:
Germany’s Green Dot for packaging

   Packaging Ordinance 1991 establishes EPR
   Packaging accounted for 1/3 by weight and
   ½ by volume of total waste stream and was
   growing!
   Would stimulate new recycling technologies
   Berlin Wall collapse meant new consumerism
   and waste and decreasing landfill space

                  Clean Production Action
Established individual or third party
system
   Fillers are responsible
   for packaging waste;
   can deal with it
   themselves or set up
   third party system

   Industry responded by
   designing the Dual, or
   Green Dot, system


                       Clean Production Action
DSD
  Non profit company, Duales System
  Deutschland (DSD) licenses logo for a fee
  Fees based on the material and weight of the
  package and paid by filler – usually the owner
  of the product brand name
  Households have 2 bins: one for regular trash
  (municipality responsibility) and one for
  packaging (DSD picks up for free)
  DSD also operates drop-off igloos for glass
  and paper

                  Clean Production Action
License fee for Green Dot, Oct 1994
Weight-based Fee: DM/kg
         3


        2.5


         2


        1.5
                                                                 materials

         1


        0.5


         0
              paper   Al        Plastic         Comp   Natural
                      Clean Production Action
Clean Production Action
DSD sets clear targets
   Recycling targets ranging from 64 to 72
   percent for various materials
   Refill rate for beverage containers at 72
   percent or higher




                 Clean Production Action
Effects of DSD: less packaging
   Between 1991 and 1995 packaging
   consumption decreased by one million
   tons
   Green Dot packaging decreased 14%
   from 1991-1995, while total packaging
   in Germany decreased 7%
   Comparison in USA (same time)
   packaging increased 13%

                Clean Production Action
Effects of DSD: product redesign
   Packaging redesign:
   lightweighting
   elimination of
   unessential
   packaging (blister
   packs)
    increased use of
   concentrates and
   refill packs

                  Clean Production Action
What about plastics?
   In 1996 plastic packaging recycling increased
   to 68%
   Move away from PVC (difficult to recycle) to
   better recyclable material (eg paper)
   Incineration not considered recycling
   BUT: One third recycling via „feedstock
   recycling‟ eg pyrolysis, hydrogenation and
   substitution of waste plastic for oil in steel
   production

                   Clean Production Action
Clean Production Action
Clean Production Action
Clean Production Action
Clean Production Action
New recycling targets from 1999
   Glass           75%              (previously 70%)
   Tinplate        70%               (same)
   Aluminum        60%               (prev 50%)
   Paper/crdbd)    70%                (prev 60%)
   Composites      60%               (prev 50%)



                  Clean Production Action
Hazardous contents must decrease
   concentrations of lead, cadmium,
   mercury and hexavalent chromium in
   packaging reduced:
    • 600 ppm (parts per million) by weight from
      30 June 1998
    • 250 ppm by weight from 30 June 1999
    • 100 ppm by weight from 30 June 2001


                   Clean Production Action
Prognos Assessment of DSD, 2002
   The recycling of two million tonnes of
   lightweight packaging avoids carbon
   dioxide pollution by the same quantity
   which arises in the incineration of 28
   million tonnes of residual waste
   Costs of the Green Dot are between
   520 and 605 euros per tonne, could
   drop to 250-370 euros
                 Clean Production Action
Greenhouse gas reductions
   By recycling used sales packaging, a total of
   67.5 billion megajoules of primary energy
   was saved
   In addition, this saved 1.5 million tonnes of
   climate-damaging greenhouse gases.

     (Source: Environmental Success Balance 2002 of
     Duales System Deutschland AG, www.gruener-
     punkt.de)

                    Clean Production Action
Future predictions for packaging in
Germany
   Predictions of 15% decrease in waste
   2000-2005 (Prognos Institute)
   No untreated waste to landfill in 2005
   will lead to more reductions (more
   reuse and recycling)
   Mechanical biological treatment will be
   used more in future (versus
   incineration)

                 Clean Production Action
Re-use in Europe
   On average in the European Union, about one
   third of the packaging for soft drinks, mineral
   water and wine is reused
   The highest reuse rates are achieved in
   Denmark, Finland, Germany and Sweden; in
   some cases more than 90 percent of the
   volume bottled (glass and PET) is reused in
   these countries.


                   Clean Production Action
  Beverage bottle reuse -Europe
WINE REUSE: Austria (83 percent); Finland
(71 percent); Sweden reuses 55 percent,
Portugal around 50 percent; Spain 32 percent
and Germany 29 percent.
SOFT DRINK REUSE: Austria, Germany,
Sweden, Finland and Portugal reuse between
one third and two thirds of the glass
packaging. Denmark achieves 80 percent,
followed by Germany with 61 percent.
BEER and MINERAL WATER: higher
               Clean Production Action
Germany’s Closed Material and
Waste Management Act 1996
   Aim to eliminate the dumping of untreated waste
   entirely within 20 years, as a result of the progress
   made in recovery technology.

   EPR in Germany extended to:
       Waste from Electrical and Electronic Equpment (WEEE)
      End of Life Vehicles (EoLV)
      Carpets and textiles
      Biowaste
      Construction waste
      Batteries

                        Clean Production Action
EU focus on Product Policy finds
PVC a difficult waste problem
   Green Opposition in
   Europe to PVC
   plastic leads to
   demands for phase
   out in cars and
   waste from electrical
   and electronic
   equipment


                   Clean Production Action
PVC is not and can not be safely
recycled
   0.1% total pvc use currently recycled
   Incompatible with potential recycling of
   other plastics – contaminates others
   High collection and separation costs
   Downcycling shifts disposal problems to
   other products/countries
   Increases toxic emissions in steel
   smelting if used as „fuel‟
                 Clean Production Action
PVC - 2nd most common plastic




             Clean Production Action
PVC – common in households




            Clean Production Action
PVC IS INCREASING GLOBALLY-
former long life pvc products to
enter current waste stream




              Clean Production Action
PVC legacy about to hit
   300 million tons PVC produced globally
   since 1960s
   Half already disposed to landfills and
   incinerators
   Half still in current use (construction
   materials = average life 34 years)
   1960s construction waste about to hit!
   So what do we do with it?
                 Clean Production Action
What does this waste legacy mean?
A BIG TOXIC PROBLEM
   If all pvc production were to cease
   today we would still face 150 mT waste
   mountain globally
   Along which comes tens of millions of
   tons of additives
   (estimate does not include short life
   products eg packaging, household
   products)

                Clean Production Action
EU Studies on PVC (2000) - Conclusions
   Amount of pvc waste to double in next 20
   years
   Mechanical recycling will not contribute
   significantly to management of PVC post-
   consumer wastes; reaching at best 18% of
   the total in 2020
   Incineration of 1 kg PVC leads in most cases
   to formation of 1 kg hazardous wastes
   Landfilling releases hazardous phthalate
   softeners and will contribute to formation of
   dioxins in accidental landfill fires
                   Clean Production Action
What does this waste legacy mean?
A BIG TOXIC PROBLEM
   If all pvc production were to cease
   today we would still face 150 mT waste
   mountain globally
   Along which comes tens of millions of
   tons of additives
   (estimate does not include short life
   products eg packaging, household
   products)

                Clean Production Action
PVC waste crisis will demand more
incineration- BIG DIOXIN THREAT

   “…the future will see a major increase
   in the recycling of PVC through energy
   recovery by incineration. This is
   because mechanical recycling levels
   appear to have peaked with no obvious
   hope of an increase to come.
      -Occidental Chemical spokesman, 1997

                   Clean Production Action
                 Chlorine
   Production




                    EDC
                                             PVC
                      VCM                                                     Stabilisers:
                                                                              e.g. Pb, Cd
Use - Disposal




                             Cl-polymer                Additives              (0,1-2,5 %)
                         (Cl-content 14-53%) (content 7-75 %)
                                                                              Plasticisers
                    HCL                                                       e.g. DEHP
                                                                              (10-60%)
                    Dioxin (production, accidental fires, landfill fires, incineration, metal recycling)

                                          Clean Production Action
Chlorine in = dioxin out
  Danish gov‟t now                                                      PVC waste on the rise
 trying to limit PVC in
 incineration waste
                                                             8
                                                                                                      7.2
                                                             7

 streams                                                     6

                                                                 4.1
 “review of data
                                                             5




                                            Million tonnes
                                                             4

 clearly shows                                               3                Total over 20 years -
                                                                               113 million tonnes

 correlation with
                                                             2

                                                             1

 chlorine input and                                          0
                                                                 2000                                 2020

 synthesis of dioxins
 and furans” USEPA                    Bags of incineration ash from pvc
                                      combusion
                          Clean Production Action
1 kg PVC produces 1kg or more of hazardous waste
residues (see photo of bags of incineration ash)
European Commission 2001
     PVC in incinerators
  creates acidic
  emissions along with
  dioxins; neutralizing these
  emissions generates as
  much waste as original
  waste stream…which then
  needs to be landfilled creating
  future toxic leaks and
     emissions.

  Incineration is NOT the solution

                            Clean Production Action
PVC-free political initiatives in EU
  • EU emergency ban of six
  phthalates in soft PVC
  teething toys

  • Restrictive policies at national
  level in place or recommended
  (DK, S, NL, D)

  • PVC-free policies at regional
  or local level
  (DK, S, NL, D, UK, A, Spain, Lux)




                                 Clean Production Action
Government initiatives
   Sweden (1999) phases out several PVC
   additives and places ban on phthalates in
   toys for children under 3; other phaseouts
     Achieved a 39% reduction in PVC beween 1994
     and 1999
   Denmark (1999) limit incineration of PVC;
   ban on lead stabilizers, substitution of PVC
   products difficult to segregate; PVC
   tax($2/kg on all pvc foils); 50% reduction of
   phthalates by 2010
                   Clean Production Action
Government initiatives…
   Germany: gradual phase out of soft
   PVC, no landfilling of PVC, no spreading
   of hazardous substances via recycling,
   phase out of Cd and Pb, use of
   chlorine-free materials in certain
   inflammable areas
      • -German EPA recommendations (1999)
   274 communitites and 6 Federal States
   have PVC restrictions
                  Clean Production Action
Local authorities restricting PVC
   Spain: 62 Spanish cities have been declared
   PVC free and award tax relief to builders who
   avoid PVC
   Anti PVC procurement guidelines in Austria,
   Netherlands, Nordic countries, UK, Japan and
   even USA
   Japan cities using non pvc pipes; increasing
   public concern and action against dioxin

                   Clean Production Action
Unions
   German Wood and Plastic Processors
   Labour Union :
 “problems associated with this material
   must be addressed…our organisation in
   Germany is committed to a medium
   term transition to chlorine free
   materials such as polyolefins and PET.”
      -Gisbert Schlemmer, GHK, 1994

                   Clean Production Action
PVC-free business initiatives
                         Wavin: No. 1 PVC pipe producer in Europe



                          “Why polypropylene is the better material”

                              “a standard plastic has been questioned
                              increasingly in recent years due to its
                              chlorine content: PVC”

                           “Rightly, polypropylene is called the „material of
                           the future‟. Because in addition to its excellent
                           characteristics, it has all the advantages for
                           ecologically clean reprocessing”




               Clean Production Action
Firefighters
   International Association of Firefighters:
 “Due to intrinsic hazards, we support efforts to
   identify and use alternative building materials
   that do not pose as much a risk as PVC to
   firefighters, building occupants or
   communities”
         Richard Duffy, OHS, 1998
   „PVC-Free Future: A Review of Restrictions
   and PVC free Policies Worldwide‟ visit
   www.greenpeace.org/~toxics
                       Clean Production Action
Nurses/Doctors
   “We support initiatives to reduce the
   harmful impact of medical waste,
   including…use of the marketplace to
   develop alternative low-toxicity
   products, eg replacing pvc plastics,
   latex and mercury
      - International Council of Nurses, 1998
 - See Health Care Without Harm
   (www.hcwh.org)
                    Clean Production Action
We need to rapidly phase out PVC
via:
   Green procurement and ecotaxes
   Producer responsibility for product life cycle
   as general policy
   Producer responsibility for PVC waste
   segregation prior to waste management
   Government responsibility to urgently
   implement MATERIAL POLICY as basis of
   environmental and industrial development

                    Clean Production Action
EPR in Europe now applied to
   End of Life Vehicles
   Waste from
   Electrical and
   Electronic
   Equipment (WEEE)




                   Clean Production Action
WHY EPR for autos?
  There are 8 to 9 million vehicles
  discarded annually within the European
  Union alone.
  This results in around 9 million tonnes
  of waste created per year
  End of life systems were often
  unregulated

                Clean Production Action
Auto shredder residue (ASR) is
hazardous
   Mixture of plastics,
   fluids, rubber, glass,
   dirt, and metallic
   fines which makes it
   hazardous waste in
   many countries
   ASR is approx 25%
   of the car, almost all
   disposed to landfill
                    Clean Production Action
Design objective of EoLV Directive
   Member states shall encourage vehicle
   manufacturers in liaison with material and
   equipment manufactures to limit the use of
   hazardous substances in vehicles;
   to improve design and production of new
   vehicles to facilitate their dismantling, reuse,
   recycling, and recovery; and
   to integrate an increasing quantity of recycled
   materials in vehicles and other products, in
   order to develop the markets for recycled
   materials (Article 4.1);
                    Clean Production Action
Recycling objectives
   Directive passed October 2000
   Members states must implement into national
   laws by April 2002
   Sets recovering and recycling rates (by 2006:
   reuse and recovery 85%; reuse and recycling
   80%) and by 2015: reuse and recovery
   95%; reuse and recycling 85%)
   Recycling does not allow incineration (but
   recovery can be energy recovery aka
   incineration)

                   Clean Production Action
Hazardous material phase outs
   Mandates hazardous material phase outs (Pb,
   Hg, Cd and Hexavalent Cr) in new cars by
   July 2003
   PVC was originally included but Vinyl industry
   lobbied strenuously against
   European Union decided to study PVC in all
   industry sectors:
     Results White Paper 2001 – confirmed PVC a
     waste problem with no sustainable solution
     Major auto manufacturers avoiding PVC
                    Clean Production Action
End of life catalyzes design change
in Japan auto industry
   Use of homogenous plastics for wider
   recycling options
   Design for repair
   One manufacturer discovered plastic which
   could be recycled for same use (cf Renault
   uses up to 25% recycled plastic in new cars)
   One manufacturer recycles fabrics from
   shredded waste for noise buffering
   Bumpers now commonly recycled

                   Clean Production Action
Brominated flame retardants
   Used in textiles, construction,
   upholstery (polyurethane foam),
   electronics (BFRs in plastic housing of
   computers)
   Now found widely in household dust
   Computer recyclers in Sweden had
   elevated blood levels (Sjodin, 2000)

                 Clean Production Action
Brominated flame retardant
chemicals: the PCBs of the 21st
century
 Developmental toxin, persistent,
 neurological toxin, reduced intelligence
 North American body burdens 10 to 100
 times higher than Europeans
 No regulations on BFRs in North
 America! Only monitoring ….

               Clean Production Action
BFR levels rising in American
women
                                          F i g . 2 P B D E 4 7 in C a lifo rn ia w o m e n

                  140


                  120       C A s eru m 1 960s, n =270

                            C A a d ip o s e , 1 9 9 0 s , n = 3 2

                  100       C A L a o s e r u m , 1 9 9 0 s , n = 5 0 , in c l. N D s

                            U S m ilk , c o m p o s it e (P a p k e )
  n g /g lip id




                   80


                   60


                   40


                   20


                    0
                        19 60s                                                   L ate 199 0s
                                                                        Clean Production Action
BFRs rising in Canadian women
                         30

                         25
      ug/kg milk lipid




                         20             47
                                        99
                                        100
                         15
                                        153
                                        Sum n=8
                         10

                         5

                         0



                          1980   1985       1990          1995    2000   2005
                                                   year

                                        Clean Production Action
BFRs the focus of industry in Europe
and Japan
   EU Directive on Waste from Electrical and
   Electronic Equipment mandates phase out of
   two classes of BFRs
   High priority on OsPar haz list
   Still no regulation in the USA
   EPA Region 9 conferences on the use of BFRs
   in IT sector, upholstery (PU foam)
      • SEE www.greenstart.org



                     Clean Production Action
WEEE and RoHS Directives (2003)
                                Directive on Waste
                                from Electrical and
                                Electronic
                                Equipment and
                                Directive on
                                Restriction of
                                Hazardous
                                Substances


              Clean Production Action
WEEE and RoHS Directives
  Sets individual producer responsibility
  Mandates Reuse and recycling targets
  with timelines
  Last owner takes back end of life
  product for free



                Clean Production Action
Why WEEE directive?
  6 million tonnes of waste from EEE generated
  every year
  Equals 4 percent of municipal waste stream
  and growing 3 times faster
  WEEE is hazardous in landfills and generates
  dioxins if incinerated
  Recycling workers contaminated by
  brominated flame retardant chemicals
  Needed to harmonize national initiatives

                 Clean Production Action
Directives on WEEE and RoHS
   Applicable to all white and brown goods
   not just IT equipment
   Objective: “a means to encourage the
   design and production of EEE which
   takes into full account and facilitates
   their repair, possible upgrading, reuse,
   disassembly and recycling” also
   “substitution by safe or safer materials”
                 Clean Production Action
WEEE and RoHS mandates:
  Pb, Hg, Cd, hexavalent Cr and the
  brominated flame retardants PBDEs and PBBs
  must not be used in products by July 2006
  Producers have individual responsibility for
  own products as of Aug 2005 and collective
  responsibility for historic waste before then
  Makers allowed to show cost of historical
  waste in price tag of new products for
  transitional period of 8 years (10 for fridges)
                  Clean Production Action
WEEE and RoHS mandates
  By Aug 2005 consumers will have free take
  back of WEEE
  Producers provide guarantee of recycling
  when placing a product on the market
  By Dec 31, 2006 member states must have
  reached average waste collection rate of 4
  kg/person/year
  Recovery targets range from 70%-80% by
  average weight per appliance; reuse and
  recycling targets 50%-75% depending on
  product type
                 Clean Production Action
Both directives leading to design
change
   Sony Japan set up own recycling centre
   All IT companies complying with RoHS
   phase outs; lead-free solder now
   common
   Apple‟s new laptop to be 100% metal
   casing as substitute for flame retardants
   in plastic

                 Clean Production Action
Basel Action Network
(www.ban.org)
   Current focus e-waste exports from USA
   PVC in cables and computers being
   burned in open fires>>>dioxins




                Clean Production Action
Producer responsibility for
chemicals: new EU Chemical Policy
   Would force chemical industry to supply information
   on health and environmental effects for all existing
   chemicals on the market
   No data; no market
   90% of all existing chemicals have no data
   If shown to be a carcinogen, mutagen, reproductive
   toxin then would need authorization to continue
   marketing
   Anticipated: 1300 chemicals will be restricted
   If no data, no market! www.chemicalspolicy.org

                      Clean Production Action
Some voluntary initiatives in USA
   Some IT companies promoting (weak)
   voluntary programs
   Over 20 states now advocating EPR
   type legislation for IT waste
   See computertakeback campaign:
   www.computertakeback.org
   See INFORM at www.informinc.org

               Clean Production Action
Minnesota taking lead
   Product Stewardship Initiative in 1999
   3 priority waste streams: paint, carpet, IT
   equipment with cathode ray tubes
   Conducted demonstation project (1999-2000)
   for recycling used electronics to aquire data
   on collection systems, recycling markets,
   costs and barriers
   Involved Sony, Panasonic, Computer World,
   Circuit City
   Over 3 months collected 575 Tons

                   Clean Production Action
Sony (Oct 2000)
   “We Make It, We Take It” initiative as a five
   year program that would begin in Minnesota
   and expand to five other states during 2001
   and go national by 2004
   Expected initiative to become profitable by
   2005
   Budget constraints put program on hold in
   2001
   For more information see INFORM “Waste in
   the Wireless World” May 2002
   (www.informinc.org)
                   Clean Production Action
IBM take back (Nov 2000)

     For fee of $29.99 per unit IBM will take
     back computers made by any manufacturer
     Owners bring it to UPS location
     Computers shipped to Envirocycle in Penn
     Only 1000 computers returned in first six
     months



                  Clean Production Action
HP volunary take back program
(May 2001)
   Will take back any manufacturer‟s
   product for fee -$34
   Consumers must box equipment and
   Fed Ex picks up from door
   Equipment shipped to HP facilities in CA
   and Tennessee
   No data on amounts/success

                 Clean Production Action
Compaq
  Fee $27.99 consumers receive a
  shipping label and pack up and drop off
  at UPS location
  UPS delivers to United Recycling
  Operates in seven midwestern states



                Clean Production Action
Proposed EPR plans in USA provide
no feedback for better design/price
internalization:

   All voluntary programs
   None include targets for collection and
   recycling
   No definition of what counts as recyling
   No reporting requirements or enforcement
   mechanisms
   Most will not pay for collection of used
   products and their transport to recyclers
                  Clean Production Action
EPR established in EU and Japan
   Why not in North America?
   Same companies!
   Best opportunities at local and state
   level for haz phase outs and closed loop
   legislation
   Integrated Product Policy a better focus
   than waste policy – puts onus on
   producer
                 Clean Production Action
California leading the way
   SB 20 in CA mirrored after WEEE
   Computer Take Back campaign inititiated EPR
   type legislation in over 20 states
   National Electronic Product Stewardship
   Initiative just disbanded with no concensus –
   enviros would not compromise on industry
   voluntary proposals
   Contact Ted Smith: www.svtc.org

                   Clean Production Action
For more information:
 Beverley Thorpe
 Clean Production Action
 Bev@cleanproduction.org
 Tel: 514 484 8647
 www.cleanproduction.org



               Clean Production Action

				
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