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Issue 10, August 2004Welcome to our regular email service. We trust you find this a useful service in keeping up to date with the Australian Resource Recovery and Recycling Industry issues and challenges. In this issue:
ACOR’s Extended Producer Responsibility Principles ACOR has developed a set of guiding principles for Extended Producer Responsibility programs, as ACOR members currently recover over 10 million tonnes of materials annually and will play a significant role in the delivery of this approach. The development of ACOR’s EPR principles is in response to the NSW Extended Producer Responsibility (EPR) Priority Statement 2004. The Priority Statement identifies sixteen wastes of concern suitable for management by EPR schemes, and our membership currently spans 11 of the 16 waste of concerns noted in the EPR Priority Statement. Five wastes will receive priority focus in 2004/05. These include: used computers, televisions, tyres, nickel cadmium batteries and plastic shopping bags. A further four products that have existing schemes in place will be monitored and evaluated for effectiveness. The products are agriculture/veterinary chemicals and their containers, mobile phone batteries and packaging. The industries producing these wastes, have been put on notice that they will need to take physical or financial responsibility for the environmental impact of their products throughout their life cycle and to reduce the amount and/or impact of their products in the waste stream.
ACOR supports the introduction of EPR initiatives where a system is not already in place for the recovery of the specific materials and supports the need for mechanism, such as EPR where the producer is responsible to recover products which contain toxic and hazardous constituents which may present a threat to the safety of the community and which may place a burden on the end of life management of the product, example motor vehicles, whitegoods, tyres, electronic equipment and mobile phones. In many cases these products require sophisticated technology to dissemble and recover component parts and significant re-engineering through research and development to redesign and substitute components currently used. The recycling industry is located at the end of the supply chain for the recovery and recycling of used materials and has limited ability to influence design of material for which it is endeavouring to receive and process. This "cascade effect" saddles end of life management responsibilities and costs with the recycler. These costs erode the margin the recycler makes for every tonne of product recovered. EPR has a chance to hold or reverse this cost and responsibility flow back to where it can be more effectively dealt with. It is an opportunity to externalise the cost and make them more transparent. In summary, the guiding principles for any EPR program as determined by ACOR are that they must be national in approach, underpinned by legislation to prevent freeloaders, must be sustainable and viable with measurable targets and incorporate better design principles. For more information: www.acor.org.au or tel: (02) 9907 0883.
ACOR supports product stewardship where responsibility is shared between all elements of the supply chain including government, consumers, brand owners, producers and recyclers for more benign or homogenous products – products that do not present a major environmental impact and where a system has been shown to be effective. Used packaging materials are considered a homogeneous product stream and the National Packaging Covenant is already in place to ensure optimal recovery. ACOR believes that EPR and product stewardship are two distinct approaches and members do not see product stewardship as a subset of EPR. However, both systems can operate in a voluntary and independent manner. National approach required ACOR does not support individual state based approaches for materials which clearly are distributed and consumed nationally. The negotiation of the National Packaging Covenant clearly demonstrated the need for national measures, given that state boundaries are irrelevant in the manufacturing distribution and reprocessing chain for any commodity. EPR programs should be developed at a national level with conforming legislation introduced by the states and not the other way round to prevent the trans-boundary migration of impacts, as cross border trading may become a significant issue. It is a well known fact that a large number of beverage containers bearing a deposit of 5 cents sold in states other than South Australia are redeemed in South Australia. This lifts the apparent local recovery rate and benefits a select number players who are importing or exporting material into a single state system. Such rorting has the potential to occur in non-national systems. Protocols and monitoring mechanisms must be put in place to prevent and discourage such activities. As recycling and reprocessing facilities become more sophisticated with greater reliance on technology, greater investment will be required. It is not practical, feasible or possible to replicate facilities in each state and indeed facilities own and operated by members require national feedstock given the economies of scale required to operate efficiently and return a profit. Funding Options Whatever system is adopted transparency and any fee charge is paramount to prevent mark ups along the supply chain. Independent bodies must administer the charges to avoid revenue being diverted. Selection of Targeted Materials ACOR members question the rationale of office paper and cigarette butts being priority wastes of concern given the assessment criteria and nature and complexity of other products identified and listed. Mattresses, for example, are currently disposed of at a rate of 1,250,000 per annum, with an average queen size bed uncompacted taking up .75 cubic metres landfill air space, weighs 28 kilograms and in total consumes 937,500m3 of landfill space per annum. In the US, 33,000,000 mattresses are produced annually and 20,000,000 discarded. Mattresses are a major problem waste not due to their toxicity, but due to the nature of the manufacture and the ability or lack of to dissemble. A small recovery facility in Victoria is grappling with the issues of mattress recovery, which comprises foam, fibre and metal. Market development Market development in any EPR program cannot be understated. Documents reviewed by ACOR are very much of a "push" approach with no "pull". We would recommend that mandatory targets be set for state and local government to increase the purchase of recycled content given the enormous buying power of government. Benefits of recycling Products made from secondary materials consume up to 95% less energy than materials made from virgin materials and significant benefits also occur in the reduction in water usage and air pollution. Precious landfill space is conserved, virgin resource conserved and jobs created. However, none of these "benefits" are being factored into purchase prices for products using virgin materials in the interest of giving secondary materials any sort of advantage or to level the playing field. EPR in action – The National Packaging Covenant At the April meeting in Adelaide of the Australian and New Zealand Environment and Heritage Ministers’ meeting, the Ministers agreed to an interim extension of the Covenant and the Used Packaging Materials National Environmental Protection Measure (NEPM) to July, 2005. The Ministers recognised the contribution that the Covenant has made in reducing waste at all stages of the packaging supply chain from raw material supply through to retailing and disposal post consumption. During 2003 and 2004 the environmental movement, local government and industry have undertaken a number of independent reviews of the Covenant. These independent studies have identified the strengths and weaknesses of the current structure. The interim extension till 2005 will allow consultation with stakeholders to find the best way to continue this unique co-operation between government, industry and the community. ACOR supports the National Packaging Covenant. However ACOR also acknowledges that a number of enhancements and changes are necessary given the likely challenges that lie ahead for the packaging industry. Based on the lessons learnt over the past five years, as well as the experience in Europe and the USA the following comments are ACOR's contribution to this important issue. ACOR’s position on the National Packaging Covenant is: Maintenance of Existing Principles
Maintain Voluntary Undertaking
Maintain Continued Funding The commitment to the transitional funding by participants and the use of these funds for programs, research and initiatives. The continued funding is considered critical to moving forward and sharing the funding across the whole supply chain, rather than just one link, to provide a fair mechanism for fund raising. Full transparency of the funds collected and spent is necessary. Enhancements In developing MK II, ACOR would like to see the following enhancements considered:- Increase power of NEPM The use of the NEPM for supply chain members that are not meeting their obligations can not be avoided. The voluntary nature of the NEPM requires a firm, fair and appropriate action can be enforced on non complying companies. The ability and authority to capture (free riders) can not be understated. ACOR believes that the following areas should be future targets:-
Promotion by the NPC Council There
are two elements of promotion identified by ACOR members which we
Introduction of KPI and measures While the current NPC looks to signatories to develop KPIs and measures to report against, measures need to extend beyond recycling rates and downgaging concepts. The introduction of a standard set of criteria and a pro-forma of measures could be used to verify performance against the objectives under the Action plans. This would enable industry and interested stakeholders to more easily recognise the advancements and the benefits of the program. Broaden the Focus to Industrial Segments The initial focus on consumers is served to establish a foundation for the NPC in the first five years, however moving forward, it is recognised that a large volume of packaging is sold into industrial sectors and the focus should now be extended to include these industry sectors and consumers. The NPC Council The role of the council needs to be increased to include the collection of data, communication of the achievements on a regular basis, to revive and enhance level of reporting to the community and increase accessibility and transparency in action plans recognising that some commercial in confidence issues should be kept to a minimum, it must be adequately funded, a central repository for all funded research - reports and data with hot links to state JRG sites were available. Consideration should be given to broadening participation to include consumer groups. State JRG Committee Representation Currently there is no consistency between state JRG committees as to who is selected to represent industry and provide a voice, for example in NSW and VIC committee's industry representation is from recognised industry groups and associations, whereas in other states, QLD, SA, and WA individuals are appointed. Our concern is where personal or company appointments are made, the delegates may present a narrow view to the committee rather than an industry perspective. Project Funding Current there is a range of methods used to disseminate funds collected, for example in VIC, funds are distributed to all councils whereas NSW funds research and development to improve recovery and determine best practice. QLD funds trial projects and SA provides subsidies only to those councils who are signatories. We believe that the funding should be provided beyond kerbside and public place recycling to other market segments and stakeholders who have a justifiable and reasonable case. Summary In summary the current philosophies of the National Packaging Covenant should be continued with a clear commitment to resist the urge for fundamental and drastic change. The Covenant should provide a forum for sharing of ideas, problem solving and developing best practice and should provide funds for research, development and implementation of new initiatives. NPC Consultation Proposal ACOR was pleased to see many of the issues and concerns noted in our submission were taken up in the 29 proposals detailed in the National Packaging Covenant Council Consultation Proposal to strengthen the covenant. ACOR supports 28 of the proposals. ACOR Opposes including Newsprint ACOR disagrees with paper being included for the following specific reasons:
The newsprint industry have demonstrated responsible product stewardship over the last 15 years and should not be included with the packaging chain and the NPC Mark II. NPC Council ACOR seeks a review of the NPC Council composition and believes that the resource recovery sector MUST be represented given it is our member’s who play a critical role in receiving and processing collected materials from both domestic, public places, events and the commercial and industrial sector. We understand that currently the Council comprises 12 representatives. Six from Government representing Commonwealth, State and Local government and six industry representatives from the following organizations: Food and Grocery Council, Australian Industry Group, Beverage Industry Environment Council, Plastics and Chemical Industry Association, Packaging Council of Australia Retail Traders Association. We understand that Government has the same number of seats. We question the composition of the Council and the validity of some organizations being present on the Council. We are mindful of the need for a workable Board and therefore feel that the composition rather than the number of players should be reviewed. ACOR’S Recycling Guides hit the mark
In 2003 ACOR hosted half day seminars in six capital cities to launch The Recycling Materials Manual comprising kerbside specifications for post consumer materials. Over 300 local government staff, contractors and interested stakeholders attended the events. National recycling managers from each of the kerbside collected materials detailed the issues and challenges of recycling each material as background to the need for national specifications. The CD also contains Recycling Guides for Manufacturers Marketing in Consumer Packaging. These products are destined to be recycled, but the selection of glues, labels and closures can assist or hinder the recyclability of a container. The project was funded through the Transitional funding arrangement of the National Packaging Covenant. A CD ROM featuring the recycling specifications and Guides from manufacturers has been forwarded to every council in Australia. Copies of the seminar presentations and specifications are available online at www.acor.org.au or by contacting the office 02 9907 0883. ACOR’s specifications are password protected so we can advise you of any changes when they occur. Acor Members demonstrate Product Stewardship MRI (AUST) PTY LTD
FISHER & PAYKEL
Electrical Waste - Televisions
Computer Industry
The Australian Council of Recyclers (ACOR) is Australia’s leading industry Association representing the major companies involved in recovering secondary resources. ACOR’s mission is to maximize resource recovery and achieve the highest resource order of Australia’s secondary materials. Efficient and effective collection and recovery of resources is a high priority for ACOR members who collectively reprocess in excess of 10.2 million tonnes of secondary resources, otherwise destined for landfill annually and directly employ over 5,000 staff. Current ACOR membership spans the following sectors:- aluminium, batteries, cardboard, computers, construction and demolition material, electronics, ferrous and non-ferrous metals, glass, mobile telephones, mobile garbage bins, paper, newsprint, plastics – HDPE, LDPE, LLDPE, PET, PVC, tyres, whitegoods and energy recovery. To find our more about members click on the members logo which will take you directly to their website.
ACOR Non Packaging Members
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