Critical Considerations Can Mean Success or Failure for an EPR Program – Environmental Leader

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.

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