A number of positive outcomes have been achieved in the last five years. For one, the scheme has diverted some 45,000 to 55,000 tonnes of TV and computer e-waste from landfill.
Through year-on-year investment by importers and manufacturers, the public has greater access to free recycling services and the number of drop-off sites has grown over the last five years.
Additionally, industry is making the e-waste recycling process more rigorous through the adoption of the collection, transporting and handling of electrical and electronics standards, the AS5377.
Noting these achievements, MRI E-cycle solutions, an approved co-regulatory arrangement under the NTCRS, is proposing "simple changes" that the government can make to improve the scheme while keeping e-waste out of landfill and minimising the material's environmental and human health impacts.
"MRI E-cycle Solutions is very committed to helping ensure the success of the NTCRS and product stewardship generally in Australia," MRI PSO CEO Rose Read said.
"The review is a great opportunity to further refine the NTCRS and enhance the resource recovery outcomes to the benefit of the community, the environment and the economy."
MRI's seven proposed changes
- Revise the waste arising calculation
The waste arising calculation should adequately account for exported reuse and hoarding, said MRI, adding because they are not accounted for, the current targets of up to 80% in 2026-27 are unachievable.
"There are two ways to deal with this, either include the volume exported for reuse in the waste arising calculation or allow product exported for reuse to be counted in an arrangement's target. There would need to be clear guidelines on what is deemed eligible exported reuse that should over time be included in the AS 5377," MRI said.
- Simplify the scheme/arrangement target and liable party volume calculations
At the moment, scheme and arrangement targets are based on the previous three years of imports while a corporation's liability and share of the target is based on the imports in the previous year. This means a corporation is unable to easily forecast the amount of e-waste it is liable to collect and recycle each year.
To simplify this, MRI has recommended that the scheme and arrangement target be based on imports in the previous year only.
"There is limited value given the maturity of the market in using three years of imports to determine the scheme target each year. This will also mean each arrangement and liable party can easily calculate their target for each year as well as provide greater transparency to all stakeholders on the percentage of free riders being covered," MRI said.
- Revise the reasonable access rule for remote and outer regional areas
The number of free drop-off sites to the public has certainly increased but MRI pointed to a lack of consistent, well-promoted collection services in outer regional and remote areas due to the costs of servicing these areas and the reasonable access requirements under the regulations.
"This is where the competitive market approach is not delivering on the objectives of the regulations. Duplication of collection points in these regions is an inefficient use of industry funds. It would be more effective for arrangements to collaborate and share resources in these regions as a way of meeting service levels expected by councils and communities," MRI said.
"To make this happen, government should revise the reasonable access rules so that they facilitate collaboration between arrangements and local government to devise and implement efficient collection programs for remote and outer regions where costs are shared equitably between all stakeholders."
- All AS/NZ 5377 auditors to be JAS-ANZ audited
The AS/NZ 5377 standard may have been implemented but MRI said its effective application by some organisations and providers has been lacking and less than rigorous.
MRI believes there is an urgent need to ensure closer monitoring of the standard's application including a more demanding audit process.
"Based on our operational experience across numerous sites, operators and downstream providers, it would appear there is a lack of adequate awareness and technical understanding of the standard and its intent," MRI said.
"To ensure all auditors are trained appropriately and to ensure consistency, each AS/NZ5377 auditor should be JAS-ANZ accredited and should undertake regular training on e-waste processing. This includes developing competencies in the management of hazardous materials and dangerous goods handling, as well as understanding offshore processing with a focus on downstream mass load balance. It should be made clear in the regulations that AS/NZ 5377 certification does not imply that the recycler is achieving the required 90% recovery rate."
- Expand the product scope
What type e-waste can or cannot be accepted through the NTCRS? This remains a point of confusion and industry, including MRI have long called for the inclusion of other electronic equipment in the product scope.
These products include television peripherals and accessories i.e. set-top boxes, DVD, CD and Blue-ray players and all other devices that are designed to extend the function and performance of televisions; audio visual/stereo equipment (speakers, CD players, amplifiers, video/digital and still cameras); routers and modems and other wireless telecommunications devices, excluding mobile phones and their accessories.
Other equipment such as self-check-out equipment/scanners, gambling equipment and UPS should also be covered by the NTCRS. More broadly, MRI E-cycle Solutions believes that the NTCRS product scope should harmonise with the same categories addressed by the EU Directive on Waste Electrical and Electronic Equipment.
- Ban e-waste from landfills
A key step towards maximising resource recovery rates and safely managing hazardous substances is prohibiting the disposal of all e-waste, including batteries, from landfills, MRI said.
MRI has thrown it support for such a ban, saying the move would directly contribute to further channelling e-waste into properly managed schemes and programs such as the NTCRS, MobileMuster, Cartridges 4 Planet Ark and FluoroCycle.
"While landfill bans are a state government responsibility, there is a need to acknowledge, harmonise and integrate their role allowing Australia to more effectively manages e-waste," MRI said.
- Raise community awareness and education
MRI noted that community awareness of the NTCRS is "very low", highlighting that to date, there has been no widespread consistent promotion of the service to the community.
"Rather it has been a series of disjointed promotions of local services by each arrangement and listing of collection sites on arrangement websites and Planet Ark's recyclingnearyou.com.au website," MRI said.
"The regulation provides little guidance on how and by whom the scheme should be promoted, nor does it foster collaboration and investment of resources into a clear and consistent message by all stakeholders in promoting the scheme.
"MRI E-cycle Solutions recommends a centrally coordinated approach to raising community awareness and educating the community about the scheme using uniform messaging. This ideally would involve co-regulatory arrangements working collaboratively and sharing the costs with the federal government to achieve an agreed level of community awareness over time."