Application of EPR in E-waste Management

concept in other countries

2 November 2015

Junya KIKUHARA
JICA Expert team

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Contents of Presentation

• Overview of Extended Producer

Responsibility(EPR) concept
• Practical aspects of EPR
• Lessons learned from good practices
• Issues to be addressed and measures
to be considered for EPR application
to Malaysia
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Overview of EPR-What is it?

• EPR is a policy principle to promote total life

cycle environmental impact of product system
by extending the responsibilities of the
producer to various parts of the entire life cycle
of the product, and especially to take-back,
recycling and final disposal of the product (Lund
University)

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Overview of EPR-What is it?

• EPR is not the concept that all the

responsibilities for recycling and treatment
are imposed solely on producers, but
shared among relevant stakeholders(OECD
guidance manual)

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EPR as “shared responsibility”

• OECD also defines

– Main objective of EPR is to shift responsibility from
municipalities, usually mainly responsible for solid
waste management to producers for managing
end-of-life products.
– In most schemes, however, municipalities remain in
charge for some aspects of the waste management.
Other actors, such as consumers and waste
management operators, are usually also involved.

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Why shared responsibility is pivotal?

• Based on EPR along with Shared Responsibility

concept, following activities are conducted
more efficiently;
– Design improvement (e.g. design enabling easier
dismantling)
– High utilization of product and material through
effective collection and recycling
– Effective collection by collaborating with
municipalities and retailers
– Environmentally sound recycling
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Why EPR as shared responsibility is
necessary?

• Problems related to product for its treatment

and disposal is becoming more complicated
– Hazardous components
– Complexity of structure
• Possibility for utilization of recovered material
• Producers who builds products and knows how
to dismantle, dispose and to utilize resource,
can be one of the primary actors to improve
the situation. But not by alone.
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What is EPR in practice?

• More specifically, EPR can be detailed out mainly;

– Physical Responsibility: producer is involved in the
physical management of the product such as for its
transportation and recycling of waste
– Financial Responsibility: producer covers all of part of
the costs of collection, recycling and final disposal of
waste
– Informative responsibility: producer supplies
information on environment properties of the product
and report relevant data and information to national
authority 8
What is “physical” responsibility?

• Can be collection or/and recycling activity

– Collection activity is divided to primary and secondary
• Primary collection can be done efficiently by such entity as
retailer or municipality collection serving closer touch point to
consumers
• Producers are normally responsible for the transportation from
the collected site onwards
– Recycling activity
• Producers directly involve in recycling activity in some countries
like Japan
• Local authority/municipality/solid waste
concessionaire are playing an important role
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Types of collection channels

• Door to door collection by Local authority or

concessionaire
• Collection depots operated by municipality
• Curbside collection
• Retail collection and pick up old for new by retailer
• Direct return to producers
• Collection event
producers can play only their part and
involving stakeholders should play their
parts as well
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Some examples in Malaysia

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What is “Financial” responsibility?

• Producers are bearing following

responsibilities
– Bears the cost for collection from collection
facilities onwards and recycling based on the
market share in EU
– Producers are obliged to pay fees to be used for
subsidy for household E-waste collection and
recycling to recycling fund management
board(RFMB) through national government,
depending on the quantity of items put on the
market in Taiwan
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Cases in EU member states

D:Distributor, M:Municipality, P:Producer

Producers are not the only responsible entity and
are responsible for secondary logistics onwards 13
Individual and collective producer
responsibility (IPR and CPR)
• EPR can also be fulfilled by producers either
individually or collectively.
• This practical idea emerged to identify who has
the physical, financial, informative and other
responsibilities in practice and regulatory
framework.
– Individual producer? Producers as a group?
• This is also emerged to create a level playing field
for promoting design for environment.
– A particular producer makes the best effort can reduce the
end-of-life cost in return.
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What is IPR and CPR?

• Individual Producer Responsibility (IPR)

– Individual producer pays for end-of-life management of
his/her own products.
– Collection quota is given by the individual producer’s
(brand)market share, e.g. in previous year.
• Collective Producer Responsibility (CPR)
– Is an approach where all producers participating in a
system agree to share the cost of recycling and collection
of all waste products, usually on the basis of units or weight
on new products sold.
– A group of producers pay for the end-of-life management
of their products regardless of brands.
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What is IPR and CPR?

• Individual physical responsibility can be

implemented when 1)the distinction of products are
made at minimum by brand and 2)the producer has
the control over the fate of their discarded products
with some degree of involvement of the
downstream operation
• Collective physical responsibility is taken when
1)products of similar kind are physically handled
together regardless of the brand and 2)the handling
is placed in the hands of a third party as Producer
Responsibility Organization(PRO)
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In reality..
• However individual physical responsibility can be
implemented in both collectively (PROs)and system
that are set by individual producers to collect and
process their own branded products.
• It is misunderstanding that IPR always implies that a
single producer develop separate infrastructure for
collection and treatment infrastructure of his or her
own products.
– Meaning to say physical responsibility imposed on brand
basis and collection and recycling can be done collectively

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Pros and cons of IRR and CPR

• Under IPR, responsibility is more clearly

identified while man power and management
work is required for brand segregation. Also
brand that cannot be identified is an issue.
Identifying brands can be a burden
– Introduced in Japan
• Under CPR, brand base management is not
necessary. Only the market share is required.
But free rider and orphan issue exist.
– Introduced in EU member states
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Case studies
• Producer and other stakeholder responsibility
• Individual or collective responsibility
• Physical and financial responsibility
• E-waste flow data management
• EPR compliance monitoring and enforcement

Japan Denmark Germany Netherlands Taiwan

What lessons can be learnt for? 19

Mechanism in Japan
(Used home appliances discharge)

Each stakeholder has shared responsibility from the discharge of used home 20
appliances to its recycling.
 Some features
• Individual consumers shoulder the collection and recycling
fee at the time of discharge (consumers have financial
responsibility) .
• Manufacturers are physically required to take back E-
waste (secondary logistics onwards) and recycle the
collected E-waste to fulfill their legal obligation
(manufacturers have physical responsibility).
• All movement of E-waste is accompanied by
manifest(Recycling ticket) and it is managed one manifest
per item by brands.
• There is Designated body established for handling the
wastes whose brand is no longer existed in the market
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Manifest -managed by brand-

Name of Unique identification number (one# per

consumer(generator) item)
Name of retailer

Name of item
Brand base management= generator
selects the brand(Sony, Panasonic,
Toshiba, etc and others 22
Denmark
Consumers Municipalities
purchase, use and collection and sorting into
disposal 5 fractions

Collective
Producers PROs
Transport
design, manufacture
coordination and Companies
and retail administration

Clearing House Treatment

(DPA-system) Facilities
registration and processing for
reporting to EU reuse, recycling and
energy recovery

Material flow
Environmental
Money flow, collective non-brand selective
Protection take back schemes
Agency Flow of information and data, collective
monitoring
Source: The WEEE Directive & Extended Producer responsibility non-brand selective take back schemes
 Some features
• Municipality must set up adequately accessible collection system
according to the population density. Thus municipality bears physical and
financial responsibility for collection
• Overall responsible organization, Clearing house(DPA)
– Handling administrative tasks of producer registration
– Receiving annual reports from producers on their EPR compliance
– Reporting relevant data to authority
• Producers must register and are financially responsible for covering cost
of E-waste treatment and do not have much physical responsibility.
• PROs are formed by producers and provide services on their behalf
– Producer registration
– Annual reporting to DPA
– Calculate member producers market share and charge them for treatment cost,
manage the coordination and payment between the municipality collection
points, transporters and waste treatment facilities and report to DPA
– Payment of financial security
• Financial guarantee needs to be paid if producers do not join PROs in
case of bankruptcy or insolvency. 24
Web base registration system

• Municipality
Producer can register online
through DPA web portal

Registered producer information25

Germany (Producers Group Scheme)

Federal Government
Central Registration
Report
Agency(EAR)
Report

Individual Maker Group

Individual
Management
Report manufacturer/
Organization importer

Pickup request
Coordination
Recycler

Municipal collection point

Household Retailer B2B

 Some features
• Clearing house(EAR) acts as overall responsible organization and
emphasize enforcement measures
– Handling administrative tasks of producer registration
– Calculating producers market share
– Verifying producers EPR compliances
– Reporting producers EPR compliance to federal government
• EAR is putting much effort minimize the free-rider problem and create
level playing field
• Producers are financially responsible for covering cost of E-waste
treatment according to the market share. Must register and use
registered number for all transaction. Also responsible for secondary
logistics for the collected E-waste to recycling facilities, according to EAR’s
request
• Financial guarantee needs to be paid by all producers for possible
bankruptcy or insolvency.
• PROs are formed by producers and provide services on producers behalf
• Municipality must set up adequately accessible collection system and 27
register to EAR if they are not able to treat themselves.
 EAR web base product registration

Product information includes “put on

market (POM)” data for current and
previous year
Netherlands
Consumers Municipalities
purchase, use and collection and sorting into
disposal 5 fractions

ICT Milieu
collective PRO
Producers registration and
design, manufacture administration
and retail transport and
treatment of waste
IT & TE

Environmental
Material flow
Assessment
Flow of money, collective non-brand selective take back schemes Agency
monitoring and reporting
Flow of information and data, collective non-brand selective take
to EU
back schemes

Source: The WEEE Directive & Extended Producer responsibility

Collection point run by municipality

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Source: http://www.weee.nl/en
 Some features
• Producers first must register and are responsible for secondary
logistics for the collected E-waste by municipalities to
recycling facilities.
• PRO(Producer Responsibility Organization) is formed by group
of producers and provide services on their behalf
– Producer registration and its registration
– Arrangement for transport and recycling of E-waste
• Producers are financially responsible for covering cost of E-
waste treatment according to the market share.
• Financial guarantee needs to be paid by all producers for
possible bankruptcy or insolvency.
• Municipality must set up adequately accessible collection
system and conduct initial sorting of collecting E-waste 31
Taiwan
Consisting of
Fee Rate Reviewing representatives of
government, academia,
Committee consumer groups,
Decide fee rate and subsidies manufactures, etc.

Announce fee Environmental Protection Administration (EPA)

rate of the year Recycling Fund Management
Manufacturers
Fees Committee (RFMC)
Report the result of audit
Subsidies
Audit
Collection and Auditing
Recycling Companies
Companies

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Some features
• Producers bear financial responsibility and pay the
cost for recycling according to the shipped volume
• Subsidy is provided for collection(including
primary) and recycling by the fund management
board (FMB) created under the government
• Strict monitoring on the proper collection and
recycling is conducted by FMB and audited by the
third party
• Independent recycling fee revising committee
established and the members are from public and
private including producers
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 Things to consider from policy perspective
in Malaysia
• Producer/importer registration and reporting
– For ensuring no free riders exist in the market
• No producers are allowed for the business unless registration is obtained.
Verification and monitoring is also inevitable
– Reporting the sale/import data is important for market share
identification and E-waste collection and recycling data
• Definition of producer and “put on market(POM)”
– To identify “sales/imported” amount, this is necessary
• Financial guarantee may be necessary
– For tackling cases of bankruptcy or insolvency and for disappearance of
producers from the market
• Producer Responsibility Organization (PRO) may be
necessary in the mechanism
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– Competition and transparency among collective system is to be ensured
Things to consider from policy perspective
in Malaysia

• National clearing house-managing entity for overviewing

the mechanism may be necessary
• Dealing with orphan products is important
• Enforcement is still a very KEY issue
– Ensuring all collected E-waste brought to “proper” place.
This needs to be monitored through the enforcement
– Monitoring false reporting, transaction without registration
can reduce the improper flow
– Enforcement by authority with the data provided by clearing
house and cooperation can be effective
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Things to consider from policy perspective
in Malaysia
• Brand based management or market share based
approach?
– How to identify and manage the market share of
producer/importer should be discussed
• E-waste management by unit or weight or hybrid in
terms of enforcement for the control on flow?
– Unit base is costly but stricter control for individual items
– Weight base (bulky) management is less costly but strong
enforcement on unit wise still necessary to avoid the
leakage
• Government initiated management or public and
private collaborative management?
– Taiwan or Denmark model? 36
Thank you very much.

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