Forget EPR: Researchers Outline Blueprint for ‘Ultimate Producer Responsibility’ for E-waste

Existing EPR systems limit electronics producers’ responsibility to national jurisdictions, not to the countries to which we export our electronics waste, and neither lead to multiple product use cycles nor to safe e-waste management.

Four researchers and 24 electronic waste experts from nine countries have
co-created an international action plan to move from waste collection and
downcycling to a more circular and sustainable approach in electrical and
electronic equipment
(EEE) management.

Their research outlines a Blueprint for Ultimate Producer Responsibility and a
science-based petition that calls for making European producers responsible for
managing their e-waste
The petition demands that the European Commission and the government of
Nigeria organize effective repair and recycling for secondhand and
via Ultimate Producer Responsibility (UPR). UPR takes international
trade in used EEE into account and includes a financial transfer mechanism from
EU-based Extended Producer Responsibility (EPR)
to countries that import secondhand EEE from Europe.

From national jurisdictions to global responsibility

Existing EPR
limit producers’ responsibility to national jurisdictions. When waste is
exported to jurisdictions outside the EPR, the producer’s responsibility does
not apply anymore. The researchers argue that existing EPR systems neither lead
to multiple product use cycles nor to safe e-waste management.

“If we observe the current international shipment of waste, a producer is no
longer responsible once the waste or used product is in another jurisdiction.
This can drive waste shipment to destinations that might not have the capacity
for sound management,” explains Kaustubh Thapa, PhD, from the Copernicus
Institute of Sustainable Development
at Utrecht University.

Professor Olawale Olayide from the University of Ibadan, Nigeria, which
conducted the research, adds: “While it is illegal to ship e-waste from Europe
to West Africa, there are many loopholes. For example, when a used phone is sent
to Nigeria, the chances are that the old phone is non-functional or becomes
non-functional probably sooner than later. However, the current system does not
hold European producers responsible for taking care of their waste in Nigeria.”

This disconnect between legality and reality neither ensures nor guarantees the
highest sustainability or circularity standards that a circular economy
requires. It might even encourage producers to evade responsibility, the
researchers assert: “Producers need to manage their
not just in one country or region but globally. When waste is ‘out of sight’, it
is also ‘out of mind’ from the producers, and this should not be the case; the
circular and just future we envision is different,” Thapa states.

EPR results in value loss, not value retention

The research finds that European EPR focuses on processes that result in the
loss of value rather than value retention. Walter Vermeulen, Professor at
Utrecht’s Copernicus Institute, states: “It is high time to upgrade these
systems by addressing the major design flaws we have identified.”

According to the research findings, EPR systems promote downcycling, which
degrades the value instead of maintaining or upgrading it.

“This focus on recycling needs to be shifted to prioritize retention options
like Refuse, Reduce, Resell, Reuse, Repair, Remanufacture and Repurpose — before
Recycling,” Vermeulen explains. “Other
shows that the Netherlands consumes 8.5 million passenger car tires every year,
recycle 100 percent of discarded tires — only a third of which are exported; yet
little is done to design tires with a longer lifespan which are easier to
reuse, re-treat and

The current system decided by producers and importers only

Another design flaw the researchers identified in current EPR systems is the
limited scope of decision-making processes, which involve producers and
importers only. This arrangement reinforces the focus on waste collection and
downcycling, and leads to a situation where high-value retention options are

“To enable and favour the necessary switch to more circularity and
sustainability of products, we recommend including those economic actors who
engage in reselling, repairing, refurbishing, or introducing new high-value
retention recycling options,” Vermeulen says. “Considering those economic actors
and giving them a seat at the table will lead to more high-value retention, and
therefore more circularity. They know how to implement these options, will
advocate for them, and change the focus from downcycling and value loss to
upcycling, maintenance and value retention.”

Beyond electronic waste — UPR generally applicable for a circular economy

The research and the resulting UPR blueprint go well beyond electric and
electronic equipment. As Kaustubh Thapa explains:

“We believe UPR should exist for more categories than just electronics. Think of it this way: The current EPR exists to manage waste in a country. UPR, on the other hand, exists to manage waste on Earth, irrespective of the country. If we look at the enormous transboundary trade and shipment of waste, such a UPR system is necessary. For a circular economy to come into existence, it is absolutely needed — and should be an integral part of any national, regional or other circular economy strategy or framework.”

Petition to the European Commission and the Nigerian Government

Based on their research findings on e-waste and secondhand electric and
electronic equipment in Nigeria, the researchers’ petition calls upon the government of Nigeria and the
European Commission to implement UPR and provides a range of ‘Recommended
collaborative actions for African countries.’ The petition requests the
implementation of UPR for producers of electronic and electrical equipment that
is exported from one country to another. A functional and enforced UPR will
reduce the ecological and health impacts of such exports and create greater
economic benefits associated with the transboundary shipment of second-hand and
discarded electrical and electronic equipment.

“The new UPR system is a significant element of the petition, but we also point
out other key elements,” Thapa says. “The inclusion of thousands of people
working in the informal waste management
and better labor conditions is one important further component. Others are
increased international collaboration to make UPR become a reality and to draw
attention to the insufficient EPR system; another one is the global right to
and its general importance for resource efficiency and a circular economy.”

The petition’s main objective is to inform consumers, electronics producers and
policymakers in Europe and Africa about problems of the existing system, about
UPR as a solution, and to generate support from people around the globe. The
researchers aim to achieve a maximum number of signatories of the petition,
which they will then take to the Nigerian government and the European Commission
to stimulate discussions around waste management and the different stakeholders’
responsibilities in view of a circular economy beyond national borders.


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