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					Submission on National Television and Computer Product Stewardship
Scheme – Calder Regional Waste Management Group

Introduction

This submission has been structured to address the questions made in the
consultation paper on proposed regulations. Our organisation generally
supports the scheme but has identified a number of concerns and issues that
will impact on the local government organisations that form membership of the
Calder Regional Waste Management Group.

Question: Is there a need to change the existing 5000 unit threshold?
What alternative threshold would be suitable and why?

The existing threshold is too high and should be reduced to around 1,000
units imported within a 3 month period. Quarterly reporting periods would
assist in the collection of accurate data over a 12 month period to ensure
adequate processes are implemented for the collection of these units at the
end of their life cycle. We can predict that the rate of turnover of computer
based technology is more likely 5 years perhaps 7 years for televisions and
although this will indicate the number of units likely to require recycling into
the future we have not collected this data at this point in time.

Question: Do you think the above measures will be effective for
managing potential avoidance by some importers?

The measures will be relatively effective however, some consideration may
need to be given in circumstances where importers go out of business – who
has liability?

Question: Are there any additional considerations that should be taken
into account when setting the target pathways for televisions and for
computers/computer peripherals?

Research undertaken in the Calder Region in 2006 indicated that residents
have stored much of their e-waste. Of the sample size of 100 residents
interviewed one hundred percent (100%) had in storage either a television, a
computer, a computer monitor or a printer. Thirty two (32%) of those
interviewed had a minimum of two e-waste items stored.

The implementation of this scheme may result in large quantities of this legacy
e-waste deposited for recycling and there will be financial implications for local
government if they are the repository for the materials which is currently the
case.

Question: Given the existing recycling rate for televisions and
computers of ten percent (by weight), do you think that 20 percent in
year one would be a reasonable starting point for the Scheme targets for
televisions and computers/computer peripherals? What are the reasons
for your view?
Whilst it is important to set targets, there are a number of issues that need to
be considered. For example is it 20 percent of the number of units imported in
the last seven year converted to mass? What do we do about the legacy e-
waste currently out there – this will impact on the collection in the first year –
should this considered as part of the 20 percent? Recycling of all televisions
and computers/computer peripherals presented for recycling in the first twelve
months will need to be financed – perhaps a standard formula could be
applied to importers to contribute financially to this and then the targets apply.

Given that televisions and computers/computer peripherals are imported as
units and the waste and recycling industry operate in volume and mass there
are further difficulties in identifying what % is recycled. A standard levy that
has the potential to be increased incrementally (dependant on the costs
associated with recycling) on all units when imported may be more effective –
the Drummuster Program is financed in this manner.

Question: Which approach in Table 1 do you consider is most effective
in setting clear and transparent requirements under the Scheme, whilst
minimising costs to approved Arrangements and the Regulator? Give
your reasons.

Approach B will allow for consistent data collection under current waste
collection arrangements. In the process of recycling the units are broken
down into components that are the sold by mass.

Question: Do these overarching principles offer a suitable basis for
specifying Australia-wide implementation requirements? If not, how can
they be improved?

The overarching principles for each arrangement are suitable, a principle
should be included for Arrangements that are cancelled or where a
participating trader ceases trading – what is the provision for contractors in
that circumstance when they still have e-waste to transport and recycle?

Question: Are there any additional types of information you consider
necessary for reporting on by Arrangements? Please give details.

The destination of the components of the collected materials is important. Not
only to ensure that hazardous materials are not exported but to identify how
these materials are disposed of. The units collected will be broken down into
components where they are not suitable for reuse and it is important to track
these individual materials.

Question: Does Table 3 provide an appropriate basis for reporting and
evaluating the Scheme?

To ensure the scheme is viable into the future, there should be reporting on
the market price received for the materials recycled. This would assist in
identifying areas where targeted market development may be required


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otherwise we may end up with large stockpiles of materials or materials
ending up in landfill.

Question: Is the list of information requirements specified in Table 4
appropriate? Please give reasons.

An additional requirement regarding data collection is required – whilst this
has been considered in table 2 as standardised data collection system applied
across all arrangements will ensure greater rigour in the data collected and
reported on – the requirement should be “the implementation of National
Television and Computer Product Data collection system”. (Which obviously
requires development)

Further Comments:

DETOX your home program organised in the state of Victoria would be a good
model for this scheme. It has a combination of mobile services and
permanent facilities. Media and educational materials are provided to local
government prior to mobile collection days.

A data collection system for the collection and processing of e-waste should
be developed to be implemented by all Arrangements, processors and
recyclers. This would ensure accurate data collection and streamline
reporting. If everyone has a different system it makes collating the data
difficult. If you make an online system available and reporting quarterly it will
be much easier to track and have update information.




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