Electronic Waste and the Circular Economy

The system of collection targets in the UK is unclear. National figures on collection rates include a significant amount of estimation about electronics that have been collected in different ways, with no clear understanding as to whether those collected electronics are treated in a high-quality manner. This leads to a perception that all is well compared to other countries that do not use these estimates. (Paragraph 30) Recommendation 1

We recommend that the Government reconsiders the use of substantiated estimates in the E-waste system when evaluating performance. (Paragraph 30) Conclusion

Targets for producer compliance schemes have been missed over recent years. For 2020 the target has been brought down to match the actual amount collected in 2019 due to the impact of Covid-19. Targets are set annually, which prevents all parties in the system from investing in long term collection and treatment. (Paragraph 36) Recommendation 2

DEFRA must set long term targets that align with existing commitments like zero waste to landfill. The targets should have milestones at clear intervals, to allow certainty for businesses and investors. They must be set using independently verified data not self-reported data. It must be clear that these are collection targets for both re-use and recycling to prevent recycling being prioritised over keeping valuable EEE in circulation—an area we will return to later in this report. (Paragraph 37) Conclusion

Our inquiry has heard that making official collection routes for the public easy and consistent is key to ensuring products are correctly re-used, repaired and recycled. Retailer take-back is an effective method, so we welcome the Government requirement for large physical retailers to offer this service. However, this further tilts an unequal playing fields away from physical stores towards online retailers and marketplaces who do not have this obligation. (Paragraph 68) Recommendation 3

Our high streets are under severe pressure and current regulations, coming into force from 2021, could unfairly entrench the competitive advantage of online retailers and 60 Electronic Waste and the Circular Economy marketplaces like Amazon. As a matter of urgency and at the latest by the end of 2021 online retailers and marketplaces must have an equal obligation to collect electronic waste from customers. (Paragraph 68) Recommendation 4

To prevent a potential loophole with take-back being offered only at remote, inconvenient warehouses, the regulations should follow the exemplary innovation shown by AO.com and DixonsCarphone. Online retailers and marketplaces for electrical and electronic equipment must arrange and pay for the collection of like-for- like electronics from customer’s homes on delivery of new electronics. They must also offer to collect any electronic waste defined as “small” at the same time. (Paragraph 69) Conclusion

A mixture of collection types is needed to tackle the significant E-waste collection challenges. As well as Retailer Take-back, kerbside collection has been shown to be very effective and easy for the public to hand-over their electronics cost-effectively and with limited damage to the environment. (Paragraph 70) Recommendation 5

The Government must make this mandatory for local authorities, with the cost paid for by producers and those smaller retailers or online marketplaces still exempt from collecting E-waste directly from the public. (Paragraph 70) Conclusion

An Extended Producer Responsibility scheme could be used to incentivise the very best practice in circular low-carbon product design. However, care must be taken to put circular economy principles at the heart of the policy and efforts made to harmonise it with wider efforts internationally. In any future producer responsibility system online marketplaces like Amazon should be responsible for ensuring that all EEE that is sold on their platforms is fully compliant with the law. Furthermore, producers should be required to pay exactly the same fees and follow the same rules selling online as they do offline. (Paragraph 71) Recommendation 6

In any future producer responsibility system online marketplaces like Amazon should be responsible for ensuring that all EEE that is sold on their platforms is fully compliant with the law. Furthermore, producers should be required to pay exactly the same fees and follow the same rules selling online as they do offline. The Government should explain how it will address all of these concerns when it publishes its consultation on new E-waste regulations in 2021. (Paragraph 71) Electronic Waste and the Circular Economy 61 Preventing E-waste and Using Resource Better Conclusion

It is welcome that Government plans to monitor progress against the Resource and Waste Strategy, including both a measure of per capita material and resource consumption and measures of resource productivity with the goal being to double resource productivity by 2050. (Paragraph 76) Recommendation 7

As a complement to the monitoring per capita material consumption there must also be a target in place to reduce consumption to a sustainable level in line with the research highlighted in this report. Due to the increasing number of electronics and the materials contained within them there should be a sub-target for per capita resource-use in electronics that is in line with this wider target. (Paragraph 76) Recommendation 8

The UK Government must confirm that it intends to follow the approach taken by other countries to ban the practice of intentionally shortening the lifespan of products through planned obsolescence. (Paragraph 85) Conclusion

Consumers have a low trust in the electronic market and the longevity of products, both new, and repaired. They lack the information to make informed choices about the balance between cost, quality and the lifetime of the products they are buying. (Paragraph 93) Recommendation 9

To overcome this issue, we recommend that the Government require producers to label their electrical and electronic products outlining the product’s expected lifetime, including how long a device will receive software security upgrades. To enhance the label to be more informative, products that are particularly durable when compared to similar products in their categories should include a “durable” accreditation. This is a method undertaken in Austria. (Paragraph 93) Conclusion

Minister Pow MP indicated that the Government is looking into enhancing and extending the minimum guarantees on electronic products, including software. We support this proposal and urge the Government to bring this forward with the aim of removing electronics with unduly short lives from the market. The expected lifetime label must be linked to the minimum lifespan guarantee. Particular attention must be paid to where the burden of proof lies between consumers and producers. (Paragraph 94) 62 Electronic Waste and the Circular Economy Recommendation 10

We support this proposal and urge the Government to bring this forward with the aim of removing electronics with unduly short lives from the market. The expected lifetime label must be linked to the minimum lifespan guarantee. Particular attention must be paid to where the burden of proof lies between consumers and producers. (Paragraph 94) Conclusion

The UK has a long history of engineering, and the public wants to be able repair their products. When products are designed, durability and repairability should be key considerations. The Government must enshrine the right to repair in law, enforcing access to (1) repair manuals; (2) access to affordable spare parts for products; and (3) ability to repair products without repairers needing access to physical or software tools specifically designed to be a barrier to independent servicing or repair. (Paragraph 109) Recommendation 11

The Government must enshrine the right to repair in law, enforcing access to (1) repair manuals; (2) access to affordable spare parts for products; and (3) ability to repair products without repairers needing access to physical or software tools specifically designed to be a barrier to independent servicing or repair. (Paragraph 109) Recommendation 12

Technology companies, repair organisations and the UK Government should collaborate to ensure safety is ensured during the repair of electronics. This could be through creating professional standards, that will in turn drive more consumer trust. This collaboration should also look at the protection of intellectual property. (Paragraph 110) Recommendation 13

The Government should mandate that products be labelled with a repairability score, based on the products design, the availability and cost of spare parts, access and ease of use of repair manuals. This will incentivise companies to go beyond the minimum requirements already established. Companies with better repairability scores should be rewarded with a reduction in modulated fees for their extended producer responsibility scheme contributions. (Paragraph 111) Conclusion

Another proposal supported by industry is a reduction in VAT on repair services from the current standard rate. This is also supported by Professor Tim Cooper and is in place in a number of countries across the EU. (Paragraph 112) Electronic Waste and the Circular Economy 63 Recommendation 14

The UK Government should encourage repairability through reducing VAT charged on the repair of electrical and electronic products. (Paragraph 112) Conclusion

Producers, local authorities and recyclers have little or no incentive to re-use products over recycling them. (Paragraph 116) Recommendation 15

The Government must increase the incentives for re-use so that all parties benefit from further re-use, in particularly making re-use evidence worth more than recycling evidence. (Paragraph 116) Conclusion

Some countries set re-use targets for electronics, such as Spain and Belgium. (Paragraph 117) Recommendation 16

The UK Government should set similar re-use targets for producer compliance schemes, with penalties levied when targets are missed. These targets must be set long term and ratchet over time to give the industry clarity and time to prepare. (Paragraph 117) Recycling Recommendation 17

Manufacturers of electronics must ensure that their products are recyclable and dismantlable by waste treatment operators. The Government must apply incentives, potentially through the extended producer responsibility scheme, for the design of products that are easy to recycle. (Paragraph 126) Recommendation 18

Producers, via producer compliance schemes, should provide information to recyclers about the materials, including quantities, in their products. A clear date should be set for this to be mandatory. Once the national material datahub is operational then manufacturers’ information should be linked to this. (Paragraph 127) Recommendation 19

We recommend that the Government fast-tracks the national materials datahub to track critical raw materials in the UK. The aspects that focus on critical raw materials, E-waste and toxic chemicals should be operational by 2023. (Paragraph 128) 64 Electronic Waste and the Circular Economy

Current recycling and recovery targets and metrics, based on weight, are not sufficient to incentivise the capture of valuable materials. (Paragraph 133) Recommendation 20

Clear targets for E-waste treatment facilities that are based on capturing value, including critical raw materials, and their environmental impact must be set. (Paragraph 133) Recommendation 21

Recycling methods covered by Best Available Treatment Recovery and Recycling Techniques, and recycling and recovery targets must be ambitious with a shift away from recovery towards high-quality recycling. There must be a clearly defined and communicated long-term pathway, with milestones, showing when and how E-waste treatment centres must improve their recycling of E-waste to capture as many materials as possible and remove toxic chemicals. This clear pathway will allow businesses to raise finance and invest in advance to reach these mandatory targets. (Paragraph 134) Recommendation 22

Government investment in low-quality Energy from Waste plants should at the least be matched by investment in higher quality recycling methods that mean materials, particularly rare and valuable ones can be re-used. Energy from Waste, though important to prevent items going to landfill, should be treated as a low priority in UK waste infrastructure investment strategies. (Paragraph 139) Conclusion

The current short-term and transactional nature of the electronic waste system is not delivering the high-quality and high-capacity recycling this country needs if it is to reach a circular economy and extract the full benefits to jobs and the economy of the precious and valuable materials currently being lost. (Paragraph 147) Recommendation 23

The Government must take strong steps to overcome the problems besetting the system by mandating that producers, compliance schemes, local authorities and AATF enter longer term contracts to create partnerships and longer-term certainty. It must also ensure that the market is regulated to a high-enough standard to prevent unscrupulous operators. (Paragraph 147) Conclusion

Increasing resource productivity by reducing the amount of resource that is extracted to make new products will be crucial to reducing the damaging impact of extractive industries on the environment and safeguarding scarce resources that are vital to a low-carbon economy. Improving the long-term price certainty of recycled materials will help recyclers invest in more capacity and improved process. (Paragraph 150) Electronic Waste and the Circular Economy 65 Recommendation 24

The Government should find ways of driving the use of more recycled materials in new products. This could be done through taxes on virgin materials, or through rewarding producers that use recycled products through eco-modulated fees. (Paragraph 150) Conclusion

There are in some cases legitimate reasons to export overseas old electronics that can have a second life. (Paragraph 159) Recommendation 25

However, due to the serious impact of E-waste on human health and the environment, both here and overseas, and the sheer quantity potentially being exported illegally, the Environment Agency should deem all electrical and electronic exports as risky and in need of more stringent requirements before exportation is allowed. (Paragraph 159) Recommendation 26

The presumption, unless proved otherwise, should be that electronics are not usable. All electronics should be tested and proved to work before exportation. No good should be exported that needs repair to be workable. There should be harmonisation of this across the UK to prevent goods being moved from one nation to another for exportation purposes. (Paragraph 160) Recommendation 27

The Environment Agency in England should be undertaking stronger enforcement activity and should be actively collecting data and information to estimate the actual quantities of E-waste being exported illegally. (Paragraph 161) 66 Electronic Waste and the Circular Economy