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 2. 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. 3.