Critical Considerations Can Mean Success or Failure for an EPR Program
Success in any industry invariably begets copycats. When a zombie movie dominates the box office, more zombie movies follow. And it’s not limited to just Hollywood. We’ve seen the same thing in public policy.
When some governments realized that privatizing services such as waste management could raise capital, many others followed. But copying success is no guarantee of continued success. There have been many bad zombie films. And there have been many instances where privatizing critical municipal services has resulted in disaster. The growth of extended producer responsibility (EPR) programs is an example of a successful approach that cannot be blindly copied with the hope of success.
EPR programs are descendants of bottle recycling programs, which have successfully recycled bottles and aluminum cans for decades. Studies show that Americans recycled 61 billion aluminum cans and 2.6 billion pounds of plastic bottles in 2011, and now recycle nearly 13 million glass jars and bottles every day. With a combination of bottle deposits, curbside recycling pick-up, single-stream recycling and educational programs, many jurisdictions have steadily increased the percentage of recyclable materials collected.
Newer programs place the financial responsibility for the recycling onto the companies that produce the products: in various jurisdictions manufacturers are responsible for collecting (and when possible, recycling) electronics, mercury thermostats, and more recently, batteries, mattresses, paint and carpeting.
Unfortunately, policy makers have often ignored the factors and considerations that drive EPR programs and the marketplace.
Establishing a proper foundation for EPR programs
As the first step in creating any EPR program, manufacturers and government officials must answer and understand five critical questions before developing EPR policies and programs:
- Is the material hazardous or toxic?
- Is the product consumable?
- What are the issues generated by the sheer size of the product/material?
- Are there secondary or inaccessible products inside products?
- Is there tangible residual value for the product material?
For example, aluminum cans are a relatively benign waste: not hazardous to store or recycle, easy to recycle (to a ready market), and they have enough residual value to make recycling financially viable.
However, some of the more recent materials that have been targeted by EPR advocates, such as pesticides, paint and certain batteries, are not. Curbside pick-up or a drop-off center for aluminum cans is safe and simple, but managing the number and location of sites for potentially harmful material, such as used oil, present several difficulties. Unfortunately, policy makers rarely make the distinction amongst these product types and focus heavily on misguided examples of accessibility.
EPR policies and the definition of “success”
Another flaw in many EPR programs is the measurement of success. EPR advocates insist on a collection target, whether in pounds or collection rates, as the fundamental metric for success. Yet for many consumable materials, such as paint and pesticides, the ideal would be for no waste to be returned for recycling. Instead, consumers should purchase and use exactly what they need and not have anything to recycle. A program that collected very little paint would probably be judged a failure, but if no paint were being discarded in the general trash, the program would, in fact, be an unqualified environmental success.
The role of the consumer
When we think of materials that can easily be recycled, we often think of newspapers, cans and bottles that can be neatly placed in a curbside container. But what about carpeting and mattresses? The primary reason many jurisdictions have targeted them is because of the impact their bulk has in landfills. Asking the consumer to drag them to the curb or take them to a collection center presents physical and logistical barriers, as well as other issues.
The solution is to remove the consumer from the majority of the recycling effort. Instead, these types of materials might be best managed through institutions and commercial organizations that have the manpower and access to process them.
Products within products: the challenges
When materials are contained within another product, processing the product can present more complex challenges. A prime example is rechargeable batteries. Almost 90% of rechargeable batteries are sold with or in the products that they power, and are often built-in and not designed to be removed. Many jurisdictions, such as New York, Ontario and Quebec, make battery manufacturers responsible for the collection of batteries within products that otherwise are not subject to regulation, such as tablets, cordless shavers or mp3 players. In addition, battery manufacturers are held accountable for collection rates, which are going to be less than ideal because of the design of the products they power. Appropriate measures of recycling success for these product types have yet to find their way into regulation.
Another challenge posed by products within products is the lack of secondary markets for the waste that is collected. Some elements of electronics have value, such as the gold in cellphones. That value, along with the salvage value in some internal components, can make recycling a computer an economically viable operation. On the other hand, some electronics have little or no intrinsic value, such as lead-based cathode ray tube (CRT) glass found in old computer monitors or televisions. Will a commercial operation invest money in a recycling facility where the salvaged material has no secondary value? Should deposit fees or government funding be used to encourage a commercial recycling operation? Creating an infrastructure for these materials is a huge challenge, as they require a different form of regulation, where jurisdictions can enable, and not just penalize, producers.
The bottom line: Copying EPR programs across materials or jurisdictions may be the current progressive waste management policy in North America, but one size simply doesn’t fit all—not in zombie movies and not in waste management.
Carl Smith is CEO and President of Call2Recycle, North America’s first and largest consumer battery stewardship and recycling program. Smith leads the organization in its efforts to help preserve the environment through responsible recycling of batteries. With more than 322 million wireless devices (phones, tablets, and e-readers) in use in the U.S. alone—all powered by rechargeable batteries—recycling both the battery and the device are more important than ever before.
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