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Computer Professionals for Social Responsibility
Position Paper on the European Union Directive on Waste Electrical and Electronic Equipment (WEEE) Ralph Grove and David Matusow
Working Group on Computing and the Environment (WGCE)
Computer Professionals for Social Responsibility (CPSR)
Abstract The disposal of electrical and electronic equipment presents a growing problem in the form of air, soil, and water pollution resulting from dumping and incineration of this equipment. This pollution includes many highly toxic chemicals that threaten human health and the environment. The proposed European Union Directive on Waste Electrical and Electronic Equipment (WEEE) proposes to mitigate this threat through environmentally beneficial changes in the production and disposal of a wide range of electronic equipment within the European Union. The CPSR/WGCE supports the WEEE and the principle of increased producer responsibility for the disposal of electronic goods on which it is based. This paper presents a brief introduction to the problems associated with the disposal of electronic equipment, an overview of the WEEE directive, and a statement of the position of the CPSR Working Group on Computing and the Environment. 1. Problems with disposal of computers and other electronic goods The world is becoming more reliant on technology. The fruits of this technological development surround us in everyday life. We commonly use cell phones, televisions, computers, and electronics are embedded in equipment of almost every type and kind. Furthermore, the growth in use of technology around the world only shows signs of speeding up.

The significance of this technological abundance can been seen in the recent uproar caused by the Y2K problem. The total cost associated with solving the Y2K problem is equivalent to that of the Apollo space program. Its estimated that the cost within the United States exceeded $500 billion, while the European Union members spent about $210 billion.

Looking more specifically at computer technology, the degree of economic impact of technology growth is indicated by the companies that operate in the arena. Firms such as Microsoft, Intel, IBM, Lucent, AT&T are near or at the top ranks of corporate growth and significance. According to the U.S. Department of Commerce, the "Electronic and other electric equipment" segment of the economy represents 261.2 billion dollars in 1997, almost 2% of the US economy.

Concurrent to the growth in the use and production of technology, of course, has been the growth in the need to dispose of obsolete and broken equipment. In 1995, there were over 21,000,000 personal computers sold in the United States. When one understands that a majority of these will become obsolete within 2 years and that the number sold is increasing, one can get some idea of the impact of the waste stream that these discarded computers represent. A 1991 study at Carnegie-Mellon University estimated that 150 million personal computers would require disposal by the year 2005. A subsequent study in 1997 modified this estimate down to 55 million, but also estimates that the equivalent of 15 million additional PCs in unwanted parts would be deposited in landfills. Disposal of this equipment would require approximately an acre of land piled four thousand feet tall in waste.

The two common means of dealing with discarded and broken electronic goods are deposit in landfills and incineration. In landfills, the toxic chemicals contained in electronic goods will over time leach into the groundwater flow and eventually into the human food chain and drinking water supply. Incineration releases these toxic chemicals directly into the air, where they are adsorbed by humans during respiration. Incineration also creates ash and slag containing toxic chemicals, which also require disposal. The lack of recycling and reuse of electronic goods also creates a need for new raw materials and therefore is a secondary cause of the pollution generated in mining and processing of these materials.

Characteristic of Electronic Waste

Appendix I shows the typical contents of a personal computer, and to what extent they are recyclable. The waste resultant from the disposal of electronics is an amalgamation of solid and hazardous waste that poses a difficult set of problems. These problems are caused by the complex nature of the equipment and the nature of the components within the waste. Among the materials that compose this waste are:

    • assorted plastics
    • chromium
    • lead
    • mercury
    • various heavy metals
There are many dangers to human health and to the ecosystem that result from disposal of these materials. Plastics contain brominated flame-retardants, which might act as endocrine disrupters, as well as other additives. Lead can have negative effects on the human nervous system, endocrine system, blood system, liver, and kidneys. A high level of lead in the body is also related to various diseases, including brain damage, cancer, cardiovascular disease, hypertension, and miscarriage. Lead accumulates in the environment and in organisms and, unlike some other toxins, does not disappear over time. Mercury enters the environment as a water pollutant and accumulates throughout the food chain. It causes brain damage in humans. Chromium is a toxic material that could damage DNA in human cells. Together, these materials form a serious pollution problem, especially when the magnitude of the waste stream is taken into consideration. 2. Sustainable Development One of the key purposes of the WEEE is to support sustainable development, i.e., development that can continue without a cumulative negative impact upon the environment. Current non-sustainable practices generate mountains of waste each year, and by using up raw materials will also make further development impossible at some point. If the current direction continues, development will start to slow. This will be caused not by some economic slowdown, but by the simple fact that raw materials cannot be obtained.

Extended Product Responsibility

Extended product responsibility (EPR) embodies an emerging principle of pollution prevention policies that focuses on the life-cycle concept of a product, and that identifies opportunities to prevent pollution and reduce energy consumption throughout the product's life. Included in this concept is the extension of the responsibility of producers to include involvement in take-back schemes in order to ensure the recycling of products and the active involvement of producers in the post-consumer stage of product life-cycle.

The purpose of the ERP initiative is to find ways for the producers of waste to be responsible for its disposal at the end of its life span. This entails several benefits, including:

    • The waste is accounted for at its end of life
    • There is a market for this waste
    • The waste does not become unmarked hazardous waste within waste processing facilities, posing a significant risk to the health and welfare of those in proximity of these facilities.
EPR has been under discussion for a very long time, and has been an important part of the search for an answer to the problem of solid and hazardous waste for over a decade. The idea has gained considerable attention since a number of European countries passed legislation promoting ERP.

EPR includes several different objectives:

    • physical responsibility for products
      A producer is responsible for the physical management of the products, used products, and the impacts of the products through the development of technology or provision of services to manage the product after its life cycle is complete.
    • economic responsibility
      A producer must cover all or part of the costs for managing wastes at the end of a product's life (eg. collection, processing, treatment or disposal).
    • liability
      The producer of a product assumes responsibility for environmental damage caused by the production, use, or disposal of a product.
    • informative liability
      The producer is required to provide information on the product and its effects during various stages of its life cycle.
There are many methods of supporting these objectives. The only limiting factor is imagination in finding solutions.

History of EPR

There have been significant developments toward implementing EPR in the last decade, including new EPR-related laws in German, Netherlands, Norway, Switzerland, and Denmark.

Germany

Most agree that the first major step towards advancing EPR was the 1991 German "Ordinance on Avoidance of Packaging Waste". This ordinance requires industry to take back, reuse, and/or recycle packaging materials. This shifts the burden of waste management from the municipal authorities to the manufacturers, distributors and retailers who generate waste.

This law was implemented without the German government dictating any specific changes, but relied upon industry to find an efficient manner to implement ERP. This was accomplished when German industry formed the Duales System Deutschland (DSD). This private entity collects and processes used packaging, and takes responsibility for each stage of the packaging process. Under the DSD system, manufacturers apply for and pay DSD a fee to place their symbol, a "green dot", on their packages to ensure that DSD will collect and recycle their packaging. Although the DSD is not responsible for the actual recycling, it does approve packaging design, and the green-dot signifies that the packaging will be recycled. This method provides information to the consumer and a funding source for recycling packaging that would otherwise be problematic. As a result of the widespread use of the green dot symbol, a sufficiently large amount of waste is identified to make the recycling economically viable. This approach to ERP forms a successful waste-avoidance system.

In 1994, Germany passed the Eco-Cycle Waste Act, which specified take-back mandates, allowing the government to impose take-back and other obligations on sellers of products. It also encouraged product responsibility on the part of product designers, producers, users, and distributors. This approach has encouraged corporations to design, produce and distribute products with Design for the Environment methodologies that include developing ways to avoid the creation of waste and to recover waste in an environmentally sound manner.

Netherlands

In March 1997, the Netherlands issued a draft entitled "Dutch Decree on Removal of Electronic Appliances". The purpose of this proposal was to require producers and importers of electronic goods to take back products free of charge for disposal or recycling. This essentially allowed a consumer to return old appliances at no extra cost. The products included in the draft decree included are televisions, CD players, computers, copiers, fax/telecommunication machines, as well as domestic products such as washing machines, refrigerators and small appliances.

The decree did not allow the cost of the recycling and disposal to be passed on to the retailers and municipalities, but did allow these costs to be passed on to the consumer. This was done to allow economic choice to decide how the costs would be borne and to place the consumer in the position of defining the proper balance for these costs within the economic system.

3. WEEE Overview The proposed European Union Directive on Waste Electrical and Electronic Equipment (WEEE) proposes environmentally beneficial changes in the production and disposal of a wide range of electronic equipment within the European Union. The directive covers three categories of equipment, large consumer goods such as washing machines, televisions, and computers, small consumer goods such as portable hi-fi equipment, and professional equipment of small and medium size. Within this group of products, the directive will reduce pollution created during manufacturing by eliminating certain hazardous materials and it will reduce pollution created during disposal by increasing the degree of producer responsibility for recycling and reuse at the end of product life cycles. The third draft of the WEEE was released by the EU Commissioners in late 1999 and a fourth draft is currently in production.

The objectives of the WEEE are simple. First, the WEEE seeks to contribute to the protection of human health and the environment by preventing air, water, and soil pollution. Current waste management practices rely upon landfill disposal and, to a lesser extent, incineration of products in question, resulting in the introduction of a variety of hazardous materials into the environment. Second, the WEEE seeks to avoid waste generation and reduce the harmfulness of waste. This is accomplished through requiring recycling and reuse of components where practical, which reduces both pollution resulting from disposal and that resulting from the production of virgin materials.

On essential aspect of the WEEE is a requirement to eliminate or reduce the use of certain harmful substances in affected products. In particular, the WEEE covers the use of lead, mercury, cadmium, and hexavalent chromium. These materials are currently used in a variety of affected products, for example as leaded solder on printed circuit boards, and in various electronic components. There are a variety of health dangers, including damage to various organs and cancer, associated with exposure to these substances, primarily a result of leaching from landfills into water supplies and into the food chain. The WEEE directs member states to establish maximum levels of use for these materials in affected products and it establishes exemptions for those cases in which no practical substitution is available.

The second essential aspect of the WEEE is an increase in producer responsibility for disposal of covered products. Responsibility for disposal of covered products currently rests primarily with municipalities, and these products currently constitute the most rapidly growing segment of municipal waste. This growth is increasing the burden on already overused landfills, and increasing the amount of toxic input to landfills as well. Requiring producers to assume more responsibility for equipment at its end of life cycle will have two benefits. First, it will allow economies of scale to be applied to disposal and recycling operations and will provide product-specific expertise to improve these efforts. Second, it will naturally encourage producers to employ manufacturing techniques that facilitate recycling and that use recycled content.

4. CPSR / WGCE Position on WEEE The CPSR/WGCE supports the WEEE and the principle of increased producer responsibility for the disposal of electronic goods. The current methods of disposal, landfills and incineration, have a clear and serious negative impact on the environment and on human health. This impact is becoming more severe as the use of electronics grows in the world economy. The WEEE directive mitigates this problem with little cost to the public and industry and is clearly in the interest of the public, both in Europe and around the world. WEEE not only addresses an immediate environmental problem in Europe, but also sets a standard for the rest of the world to follow that will move us all closer to truly sustainable production of electronic goods. In particular, we support the WEEE for the following reasons:
    • The primary expected benefit of the WEEE would be the reduction of pollution that would occur in two different ways. First, the introduction of toxic material into air, water, and soil would be reduced through the reduction of the amount of hazardous material contained in waste equipment sent to landfills and incinerators. Second, the environmental impact of producing new virgin raw materials would be reduced through increased reuse and recycling of equipment at the end of its life cycle.
    • As a secondary benefit, the WEEE would be likely to lead to improvements in manufacturing, including a reduction of hazardous materials in workplaces where covered equipment is produced and a cost savings resulting from the reuse of obsolete components. This benefit would have an impact broader than the European market as well as the electronics industry becomes familiar with responsible manufacturing techniques.
    • Other secondary benefits of the WEEE include reduced cost of waste collection and disposal for municipalities and the creation of jobs in the recycling industry.
    • The estimated costs of the WEEE are minimal. The EU estimates an average impact on costs for covered equipment on the order of 1%. This cost increase is likely to be temporary, however, as producers improve the efficiency of products with regards to reuse and recovery of components.
    • The WEEE is feasible. Substitutes for the materials subject to being eliminated under the WEEE are now available. In the few cases where replacement of hazardous substances would be difficult or unduly expensive, exceptions have been written into the WEEE. Recycling will require an initial investment and effort to establish, but there is no technical obstacle to this part of the WEEE.
    • The WEEE is acceptable under current international trade laws. The GATT article XX and the TBT agreement both recognize the right to implement measures "necessary to protect human, animal or plant life or health". The WEEE clearly falls into this category and it does not discriminate in any way between domestic and foreign manufacturers.
    • The WEEE is supported by US and European environmental groups. In the US, the WEEE has the support of the Silicon Valley Toxics Coalition (www.svtc.org), a recognized proponent of environmental consciousness in the electronics industry. In Europe, the WEEE is strongly supported by the European Environmental Bureau (www.eeb.org), a consortium of many European environmental organizations.
The environmental impact of disposal of electronics and electrical consumer goods presents a clear danger to human health and to the environment, in Europe and in other developed countries as well. The contamination of ground water, air, and the food supply through landfill and incineration of such products can be expected to continue and to grow if nothing is done to remedy the situation. The WEEE is a significant positive step towards reducing this pollution, which it will do by encouraging cleaner production, increased recycling, and cleaner disposal of affected goods. The experience of implementing WEEE in Europe will also provide benefits in other countries, as manufacturers learn to produce electronic goods with less waste and with less use of toxic materials. Appendix I. Composition of a Desktop Personal Computer
 
Lbs that can be recycled
Amount

(in lbs)

Recycle Percentage
Contents
Monitor
0.1900
3.8000
5%
metal joining, radiation shield/CRT, PWB
9.8400
12.3000
80%
structural, magnetivity/(steel) housing, CRT, PWB
0.4200
0.6000
70%
metal joining/PWB, CRT
6.8000
8.5000
80%
structural, conductivity/housing, CRT, PWB, connectors
3.7800
4.2000
90%
Conductivity/CRT, PWB, connectors
0.0000
0.1000
0%
in vacuum tube/CRT
0.4080
0.5100
80%
structural, magnetivity/(steel) housing, CRT, PWB
0.7920
1.3200
60%
battery, phosphor emitter/PWB, CRT
0.0000
0.1000
0%
red phosphor emitter/CRT
0.0000
0.0000
0%
green phosphor activator, dopant/CRT, PWB
0.0000
0.1000
0%
red phosphor emitter/CRT
0.0000
0.1000
0%
phosphor activator/PWB
0.0850
0.1000
85%
structural, magnetivity/(steel) housing, CRT, PWB
0.0000
0.1000
0%
structural, magnetivity/(steel) housing, CRT, PWB
0.0000
0.1000
0%
diodes/housing, PWB, CRT
0.0000
0.1000
0%
battery, glu-green phosphor emitter/housing, PWB, CRT
0.0000
15.0000
0%
glass, solid state devices/CRT,PWB
22.3150
47.0300
Total for Monitor
Computer
2.7600
13.8000
20%
includes organics, oxides other than silica
0.0000
0.1000
0%
Semiconductor/PWB
0.0000
0.1000
0%
Semiconductor/PWB
0.0000
0.1000
0%
Capacitors/PWB, power supply
0.0600
0.1000
60%
transistor, rectifiers/PWB
0.0000
0.1000
0%
thermal conductivity/PWB, connectors
0.0990
0.1000
99%
Connectivity, conductivity/PWB, connectors
0.0000
0.1000
0%
pigment, alloying agent/(aluminum) housing
0.0800
0.1000
80%
resistive circuit/PWB
0.0950
0.1000
95%
Connectivity, conductivity/PWB, connectors
0.0980
0.1000
98%
Conductivity/PWB, connectors
0.0000
0.1000
0%
wetting agent in thick film/PWB
0.0000
0.1000
0%
Decorative, hardener/(steel) housing
0.0007
0.0010
70%
rectifiers/PWB
0.0000
0.1000
0%
welding allow/housing
0.0500
0.1000
50%
thick film conductor/PWB
0.0950
0.1000
95%
thick film conductor/PWB
0.0000
0.1000
0%
batteries, switches/housing, PWB
0.0000
0.1000
0%
doping agents in transistors/PWB
3.3377
15.5010
Total for computer
25.6527
78.0319
Total for computer and monitor
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Created before October 2004
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