This Manifesto has been developed by the eDay Trust, a not-for-profit charity established in 2010 to pursue a long-term product stewardship solution for electronic waste (eWaste) in New Zealand. There is widespread support from local communities, territorial authorities, recyclers and industry for sustainable options that ensure eWaste is responsibly recycled and diverted from landfills. We are calling on all political parties to support a sustainable plan for addressing New Zealand’s growing mountain of eWaste.

Electronic waste was first highlighted as a growing problem for New Zealand in 2006 in a report prepared for the Ministry for the Environment by Computer Access New Zealand, the predecessor to the eDay Trust (Source 1). At that time it was estimated that there were 16 million computers and TV sets that would be reaching end of life within five years and a further 1 million new digital devices were being sold each year. Concerns were highlighted about the negative environmental and health impacts on uncontained ewaste materials such as plastics, lead, barium, beryllium, cadmium, hexavalent chromium, selenium, mercury and arsenic.

The solution recommended in this report was to follow in the footsteps of other countries and develop a product stewardship scheme for ewaste. This would ensure producers and importers of electronic equipment took responsibility for ‘taking back’ and recycling equipment when it reached end-of-life. In effect, a small levy would be added to the price of all electronic equipment and this would be held by an industry-managed organisation to fund the costs of responsible recycling.

Since 2006, there have been a number of short-term schemes including eDay, RCN e-Cycle and TV Takeback, to try and address the growing mountain of ewaste, but after 10 years New Zealand still does not have a sustainable solution.

The Ministry for the Environment estimates the total size of the ‘ewaste problem’ at between 72,000 and 85,500 tonnes of electronic waste each year, with TVs, computers and computer equipment accounting for about one quarter of this. Every New Zealander is currently producing 19kg of ewaste, which is similar to Australia, the USA and Canada. But by 2030 it is projected we will all be producing 27kg per person (Source 2).

The world is also facing a future crisis in the availability of the scarce materials used to manufacture electronic equipment – materials such as gold, silver, copper, nickel, lithium, cobalt, tantalum, gallium, indium and neodymium (Source 3). It is much less expensive to extract these materials from ewaste, for reuse, than mine for new materials.

1. All suppliers of electronic equipment (producers and importers) contribute to an industry-led product stewardship scheme no later than 30 June 2020.

2. Consumers are able to easily dispose of end-of-life electronic equipment at no cost.

3. All electronic equipment is banned from landfills.

Product stewardship relies on partnerships between governments and industry. In New Zealand, Government provided the legislative framework in 2008, by enacting the Waste Minimisation Act. This provided a framework for product stewardship across all waste streams including ewaste. By 2008 industry working groups from the computer and electronics sectors had developed two draft product stewardship schemes – one for TVs and the other for IT equipment (computers, printers etc.). The missing link in 2008 was a commitment from Government to develop regulations to ensure compliance by all industry players and maintain a level playing field in a highly competitive marketplace. The Government’s preference has been for voluntary industry-led product stewardship schemes. However the electronics industry has made it clear for the last decade that no progress would be made without an element of compulsion from Government in the form of regulations.

Government has supported the preparation of numerous surveys and reports since 2006 but has appeared reluctant to act on the findings of these reports. (Source 4,5,6,7,8,9,10,11)

In 2016, Consumer NZ reached a similar conclusion, “We think a broad mandatory scheme is needed to deal with a waste issue that’s only going to grow. Why is it so difficult to determine the scope of a regulatory e-waste scheme? Other countries are successfully using mandatory schemes to stem the flow of e-waste. (Source 12)

The Waste Minimisation Act 2008 has provisions for both voluntary and compulsory product stewardship. While some industries have responded with voluntary schemes, no universal scheme for consumer ewaste has been implemented in the last decade (Source 13). In the event that voluntary schemes are not established, the Act includes a provision for the Minister to intervene and declare a product a “priority product”, which then triggers a process that would result in a compulsory product stewardship scheme. In 2015, there was overwhelming support from stakeholder groups for ewaste to be declared as a priority product, with 85% of 216 written submissions supporting this (Source 14). Despite calls from local authorities and Local Government New Zealand (LGNZ) for the Minister to take this action (Source 15) successive Ministers have refused to do this. A report prepared by the eDay Trust also provided an economic argument for government intervention (Source 16).

We call on government to acknowledge that current approaches are simply not working and that the ewaste problem will only get bigger. The Minister for the Environment must, under the terms of the WMA:2008, declare ewaste as a ‘priority product’ and set a timetable for a national mandatory ewaste product stewardship programme.

Consumers must be able to dispose of ewaste easily and at no cost. This will create the right incentives for consumers to separate ewaste from other waste and ensure that hazardous materials are not buried in our landfills. The strong public support for the nationwide eDay collection events held from 2006 to 2010 demonstrated that consumers are willing to make the effort and dispose of ewaste responsibly provided they can do this easily and at no direct cost (Source 17). Efforts to charge for ewaste at the time of disposal have failed – both from the perspective of consumers and recyclers. New research has revealed that only 9% consumers supported collection schemes that involve charges at the time of disposal (Source 18). Consumer research has consistently revealed a consumer preference for the costs of recycling to be included in the price of new products.(Source 19,20)

Product stewardship schemes provide a mechanism for generating the funding necessary for sustainable ewaste recycling schemes. During the last decade, Government has spent around $20 million on short-term ewaste schemes, but none of these has resulted in an ongoing sustainable solution. To the contrary, two have resulted in acrimonious legal action, one of which forced the government’s recycling partner into liquidation (Source 21).

We suggest that after 10 years there is more than sufficient evidence that a project-based approach for addressing the ewaste problem does little more than raise awareness of the problem. And one thing is certain – this problem is not going away. Our rate of consumption of electronic goods is accelerating with increasingly short equipment lifecycles; consumers are well aware that is it becoming less expensive to purchase a new printer than buy the consumables for an existing printer and certainly most never even consider repairing a broken device.

New Zealand urgently needs a robust national ewaste product stewardship framework, based upon the principle of ‘producer responsibility’. International best practice encourages a balanced collaborative model which draws upon management expertise of industry, alongside appropriate engagement of consumers, local communities and government. The key action required by Government is to develop product stewardship regulations which ensure achievement of social expectations and environmental standards (Source 22), with monitoring and compliance funded as part of the product stewardship scheme(s) design.

Some local authorities have become so frustrated with the lack of progress in developing a permanent solution for recycling ewaste that they have discussed legislating a ban on electronic waste in landfills. Even for landfills with ewaste collection facilities as part of their recycling centres it is a challenge to encourage consumers to pay $20 to recycle their TV or computer monitor when they can take the same item to the landfill and pay no more that $1-2 over the weighbridge.

However, despite the potential harm from dumping hazardous materials in landfills, the risk of fly tipping presents a much greater risk than managed landfills. Without convenient drop-off facilities, there is a high risk that consumers will vent their frustration by simply dumping their old electronic equipment wherever they can find an unmanaged piece of land or waterway. So this is question of making sure the ‘horse is before the cart’, i.e. free and convenient take-back facilities are widely available – that will be the time to start to impose landfill bans. The Telecommunications Carrier Forum (TCF) has led the way with an accredited product stewardship scheme for mobile phones (RE:mobile). In their latest report they proudly claim to have 311 public drop-off points that in FY 2016 collected 105,317 phones, diverting 12.5 tonnes of potentially harmful substances from landfills (Source 23). In FY 2017 similar numbers of phones were collected – 101,613 (Source 24). Every 2degrees, Spark and Vodafone retail store provide collection facilities; postal options are available for those in regions where these stores do not have a presence.

The challenge for other ewaste such as TVs and computers is much greater. Collection sites are relatively rare and even in centres where there is a collection facility or an ewaste recycler, the general public does not know where they are located. Posting old TVs and computer equipment is not even an option. In 2010, the Government funded computer recycler RCN and the Community Recycling Network (CRN) to establish a national network of ewaste collection centres (e-Cycle). Thirty five centres were established in partnership with local authorities and community recyclers. Consumers were required to pay to drop off ewaste with prices ranging from $5 for a desktop computer to $20 for a TV. But the economic model proved wrong. Local partners were required to meet the cost of freight to Auckland to RCN’s recycling facility and this resulted in some community facilities going out of business. The pressure of the TV Takeback programme proved too much for RCN, even with a $20 government subsidy for every TV returned for recycling. In 2014, RCN was put into liquidation, stranding partners around the country who had collected equipment in good faith.

As with previous under-funded ewaste projects, the Government had to step in and fund the recycling of the 90,000 ‘stranded’ TVs.

This experience in attempting to develop an ewaste collection model based on ‘user-pays’ at the time of disposal, even with a government subsidy, has been an embarrassing failure. The value of an industry-managed product stewardship scheme is that the levies on suppliers can be continuously adjusted to reflect actual costs of recycling including the cost of collection and transport, rather than rely on a fixed government subsidy.

Government (central and local) must resist any calls to ban ewaste from landfills until effective collection and recycling systems are in place. But when these systems are in place, we expect a nationwide landfill ban on ewaste to be implemented.

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