Extended Producer Responsibility Evaluation

Transcription

1 Final Report Extended Producer Responsibility Evaluation Product Management Alliance February, 2012

2 This report has been prepared for the use of the client for the specific purposes identified in the report. The conclusions, observations and recommendations contained herein attributed to SAIC constitute the opinions of SAIC. To the extent that statements, information and opinions provided by the client or others have been used in the preparation of this report, SAIC has relied upon the same to be accurate, and for which no assurances are intended and no representations or warranties are made. SAIC makes no certification and gives no assurances except as explicitly set forth in this report SAIC All rights reserved.

3 Extended Producer Responsibility Evaluation Product Management Alliance Table of Contents Table of Contents List of Tables List of Figures Executive Summary Section 1 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES What is Extended Producer Responsibility? Summary of EPR Programs in North America Reasons and Objectives Cited for EPR Voluntary Product Stewardship Section 2 EPR GOALS, OBJECTIVES, AND RESULTS Summary of EPR Objectives and Outcomes Analysis Batteries Electronics Fluorescent Lamp Mercury Automobile Switches Mercury Thermostats Packaging and Printed Paper Paint Section 3 NON-EPR POLICY MECHANISMS Non-EPR Policy Mechanisms Section 4 FRAMEWORK EPR EVALUATION Introduction Legislative and Regulatory Process Clarity of Goals and Objectives Flexibility Program Performance and Cost Transparency Conclusion Section 5 EPR PROGRAM CASE STUDIES E-Cycle Washington Program Summary of Program and Operations Cost and Effectiveness of E-Cycle Washington Ontario Blue Box Program File: / Producer Responsibility Eval

4 Table of Contents Summary of Program and Operations Cost and Effectiveness of the Blue Box Program Maine Fluorescent Lamp Program Summary of Program and Operations Cost and Effectiveness of the Prior Government Programs North Carolina Mercury Automobile Switch Program Summary of Program and Operations Cost and Effectiveness of the Program British Columbia s Unplugged Program Summary of Program and Operations Cost and Effectiveness of the Unplugged Program Section 6 CONCLUSIONS Appendix Excerpts of United States and Select Canadian EPR Laws List of Tables Table 1-1 Products Covered by EPR in the United States and Canada Table 1-2 Common Product-Specific Reasons for EPR Table 1-3 EPR Goals and Objectives Identified in State and Provincial Laws Table 2-1 Summary of EPR Objectives and Program Outcomes Table 2-2 Canadian E-Waste Program Performance Indicators Table 3-1 Applicability of Non-EPR Policies to Common EPR Policy Goals Table 5-1 Recovery Results of E-Cycle Washington Table 5-2 Schedule of Small Electrical Appliance Advanced Recycling Fees List of Figures Figure 5-1 Blue Box Program Cost History Figure 5-2 Recycling Rate and Unit Cost Trends Figure 5-3 CFL and Incandescent Lamp Shipments Plus CFL Market Share, by Year ii SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

5 EXECUTIVE SUMMARY Introduction Extended producer responsibility (EPR) is an environmental policy approach in which a producer s responsibility, physical and/or financial, for a product is extended to the post-consumer stage of a product s life cycle. There is increasing interest in considering whether extended producer responsibility policies should be expanded in North America in order to assist in progressing toward the attainment of environmental objectives for manufactured products and packaging. There are 63 existing legislated EPR laws/programs in U.S. states and 58 EPR laws/programs in Canadian provinces. Because waste management is considered to be a local and state/provincial responsibility, there are no national-level EPR laws in either country. These laws cover a number of products types including batteries, electronics, mercury containing devices, paint, household hazardous wastes, packaging and printed paper, and other products. The purpose of this project was to evaluate whether legislated EPR policies as implemented, especially those in the United States and Canada, have met their intended objectives. This evaluation was performed by reviewing laws to identify their objectives, reviewing program reports to obtain objective data and information for operational EPR programs, and interviewing stakeholders associated with the laws and EPR programs to obtain their perspectives. While in some cases data for voluntary industry (non-epr) programs are presented in comparison to EPR programs because of the perspective provided, it was not an objective of this project to examine all such industry programs or evaluate them in comparison to EPR programs. Objectives of EPR The most common reasons cited by those who promote EPR include: End-of-life management cost shift to provide more comprehensive and sustainably funded systems by shifting costs from local governments to producers. Cost equitability so that consumers and producers pay the cost of their own consumption/production, rather than spreading the cost of end-of-life management equally over all taxpayers or all ratepayers. Pollution reduction through recycling or more properly managing hazardous materials. Product/package redesign for reduced waste and use of toxins. Sustainability to use renewable resources, reduce natural resource consumption, and provide for green jobs. Landfill diversion to minimize landfill space consumption. File: / Producer Responsibility Eval

6 EXECUTIVE SUMMARY Disposal handling problems of certain products may mean that they can be more cost-effectively managed through non-municipal recovery infrastructures. Recycling market development for products with minimal recycling market demand. Individual state and province EPR laws and regulations identify some of the above objectives, and in some cases identify specific goals for each program as well. It should be noted that some of the same objectives are also cited by local, state, and federal laws/programs for recycling and management of products and packaging and household hazardous waste materials specifically pollution reduction, sustainability, landfill diversion, and recycling market development objectives. EPR Programs Performance in Meeting Objectives Of the programs evaluated in this study EPR in North America has had mixed results, based on comparison of stated goals with available performance data. It should be noted that most EPR programs are still in early implementation phases and data is often lacking, especially full cost data. Furthermore, a number of EPR laws lack specificity in terms of measurable goals or data reporting that is indicative of whether goals and objectives are being met. Even when there is specificity in goals, in almost no cases are the goals tied back to broader public objectives. For example, a number of EPR laws seek to remove materials with heavy metals from landfills because those heavy metals can leach, become waterborne, and be released into the environment. EPR reports typically state how many pounds of batteries or electronics are recycled, but no indication is given of the amount of heavy metals removed, so the cost and effectiveness of programs for different products cannot be compared to each other or to releases from other sources. The common goal cited by advocates of EPR is to shift costs from general local tax or ratepayers to product manufacturers and/or the specific consumers of the products. There are two commonly stated objectives for shifting costs: (1) fairness (the polluter pays); and (2) provide an additional incentive to designers to design for the environment. The first objective of shifting costs is met under EPR because the endof-life management cost of covered products is paid by the individual consumer and no longer spread over general tax/rate payers. However, there was no indication that the second objective was met. In some cases, the way programs are financed (through fees consumers directly pay) flow directly to EPR programs with no financial involvement by and no incentive to producers. Furthermore, virtually all stakeholders interviewed, whether generally for or against EPR, indicated their belief that EPR does not seem to drive design for the environment. Improvements generally are being driven by the desires of companies to remain competitive and meet the demands of their customers with respect to environmental performance, and in some cases by non- EPR laws or standards. It is not an explicit objective of most EPR laws that programs under EPR be more cost effective (efficient) under privately managed EPR programs than under municipally operated programs. However, many consumers, governments and industry would ES-2 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

7 EXECUTIVE SUMMARY likely agree that it should be an objective. EPR adds bureaucratic costs via oversight of EPR programs by state and provincial governments. These bureaucratic cost increases are sometimes offset by reduced operational costs, at least for some product categories. However, very rarely is there total system cost data, including the costs of government regulatory staff, costs incurred by the public in participating/transporting products, and administrative costs of regulated producers. In most cases only tracked program direct and overhead expenses are reported. There are indications that net recycling costs may be lower under EPR programs for some products in some locations. Examples are electronics in Washington, Minnesota and certain other states, spray paint cans in British Columbia, and paint in Oregon. For these programs the cost reductions appear to be related to streamlined administrative expenses, improved program efficiencies, and stronger pricing power that comes from private management of statewide or province-wide collection and recycling programs. While operational costs under EPR have fallen for some products, for other products costs have risen. Examples are packaging and printed paper in Ontario, where per ton costs have increased by nearly 50 percent in the first seven years under EPR, and in British Columbia where the cost to manage small (non-hazardous) electrical products under EPR will likely be over ten times the cost of managing them through the existing municipal disposal system (cost reduction is not an objective of EPR in British Columbia). With respect to a framework approach to EPR, there was not a clear indication whether it is more effective in meeting objectives compared to non-framework EPR, so no conclusion is drawn regarding whether it is preferred or not preferred as an approach to EPR. Conclusions The most successful EPR programs evaluated in this study in terms of increased product recovery and cost efficiency are perhaps paint EPR programs and electronics EPR programs (but only in selected states), where industry has flexibility and control over program design and operations. However, the program reports indicate that EPR programs have not met other EPR goals, such as reducing paint generation, increasing paint reuse, increasing electronics reuse, or driving design for the environment. Most states and provinces that have EPR laws have sought to fully transfer responsibility, both cost and operationally, for end-of-life management of products to producers with no remaining government role other than regulation. There are certain obstacles and barriers to recovery (e.g., consumer participation) that producers may not be able to influence as effectively alone than if government retains a role. The lack of supporting governmental policies (e.g., disposal bans) and enforcement support has limited the effectiveness of many EPR programs. For example, the locations with the highest recycling rates for mercury auto switches are in North Carolina, an EPR state, where the state is very active in inspecting auto recyclers to enforce disposal bans, and in Minnesota, which is not an EPR state, but where there is strong auto recycler regulation by the state. The state with the highest diversion rate of mercury File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC ES-3

8 EXECUTIVE SUMMARY thermostats is Maryland, which is not a thermostat EPR state, but which does have an active government/utility role in thermostat replacement and end-of-life management. In summary, from a collection quantity standpoint, the most effective diversion programs are those where government plays an active supporting role through programs, policies, and enforcement, not because there is a mandate on producers through an EPR law. State and national government policies have also been more effective than EPR in meeting other environmental objectives, such as design for the environment. Partnerships between government and industry, that are mutually supporting, and that draw upon the strengths of each to remove barriers to increased diversion, can further the achievement of environmental objectives for end-of-life products and packaging. ES-4 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

9 Section 1 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES This section: Includes a definition of extended producer responsibility; Explains generally cited reasons and purposes for EPR; Provides a tabulation of products covered by EPR legislation in the various U.S. states and Canadian provinces; and Provides a tabulation of reasons, goals, or criteria for EPR, including measurable targets, if applicable, identified in the various U.S. state and Canadian province EPR legislation. What is Extended Producer Responsibility? Different individuals use terms that refer to the involvement of producers 1 in the endof-life management of products and packaging in different ways. There are a number of state Product Stewardship Councils that advocate for extended producer responsibility. Similarly, many of the Canadian stewardship organizations (e.g., Stewardship Ontario) and provincial stewardship regulations are for the implementation of extended producer responsibility policies. It is therefore necessary to define what the terms extended producer responsibility and product stewardship mean in this document. Product Stewardship means that all parties involved in designing, manufacturing, selling, using, disposing, recovering and recycling a product take responsibility for environmental impacts at every stage of that product's life. Extended Producer Responsibility is an environmental policy approach in which a producer s responsibility, physical and/or financial, for a product is extended to the post-consumer stage of a product s life cycle. There are two key features of EPR policy: (1) the shifting of responsibility upstream to the producer and away from municipalities, and (2) to provide incentives to producers to take environmental considerations into the design of the product. 2 EPR is a subset of Product Stewardship that is characterized by government defining, through legislation or regulation, Product Stewardship responsibility requirements for each party involved in the product s life. 1 Producers are normally considered those who design the product or package, or are a first importer in the case of goods that come from outside a state, province, or country. 2 This is the most common definition for EPR and comes from the Organization for Economic Cooperation and Development (OECD). File: / Producer Responsibility Eval

10 Section 1 There are types of end-of-life management programs or financing approaches, driven by legislation, that technically meet the definition of EPR, but that most people do not commonly consider to be EPR. In this document, we also will exclude these types of programs and funding mechanisms from our discussion of EPR. Examples of such programs are beverage container deposit-return systems mandated by law in ten U.S. states and eight Canadian provinces. These systems vary in terms of whether producers, through their distributors and retail outlets, physically take back empty beverage containers, and the extent to which producers fund the operation of the systems. In Vermont, for example, producers or their agents physically take back deposit containers collected by retailers and redemption centers and pay those return sites a handling fee to help offset the cost of operating the return system this clearly meets the formal definition of EPR. In other deposit states, such as California s and Hawaii s, producers and their distribution chains do not operate the return systems, and the states manage system funds that may include payments/incentives to local governments, recycling collectors and processors and sometimes end users of collected recyclables. There are also end-of-life programs that some may consider to be EPR, but which are not considered to be EPR in this document. Examples include advance disposal or recycling fees (ADF, ARF) collected by governments. For example, Washington DC assesses a five-cent fee on disposable plastic or paper single-use carryout bags, which funds clean-up of the Anacostia River. Other examples include advance fees on tires, which governments often use the funds to clean up illegal tire stockpiles and subsidize tire collection, processing, and/or markets. California s electronic waste recycling system and used oil recycling system also fit into this category. The State of California manages the collection of fees from retailers and the disbursement of payments to recycling collectors and processors. Producers have no involvement in funding or operating the system and so, even though in some respects there may be operational similarities to electronics EPR programs in other states, it is not considered to be EPR in this document. Summary of EPR Programs in North America The following table lists EPR programs and covered products in the United States and Canada. 1-2 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

11 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES Product UNITED STATES Arkansas Table 1-1 Products Covered by EPR in the United States and Canada Batteries Electronics Mercury Auto Switches Mercury Thermostats Fluorescent Lights Paint Pesticide Containers Pharmaceuticals Other Household Hazardous Oil/Filters Tires Carpet Packaging and Printed Paper Beverage Containers Other Electrical Items California 1 2 Connecticut Florida Hawaii 2 Illinois Indiana Iowa 2 Louisiana Maine 2 Maryland Massachusetts 2 Michigan 2 Minnesota Missouri Montana New Hampshire New Jersey New York 2 North Carolina Oklahoma Oregon 2 Pennsylvania Rhode Island 2 South Carolina Texas Utah Vermont 2 Virginia Washington West Virginia Wisconsin US Totals File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 1-3

12 Section 1 Product CANADA Batteries Electronics Mercury Auto Switches Mercury Thermostats Fluorescent Lights Paint Pesticide Containers Pharmaceuticals Other Household Hazardous Oil/Filters Tires Carpet Packaging and Printed Paper Beverage Containers Other Electrical Items Alberta 3 2 British Columbia 2 Manitoba New Brunswick 2 Newfoundland 2 Nova Scotia 2 Ontario Prince Edward Island 2 Quebec 2 Saskatchewan 2 Canada Total Sources: Product Stewardship Institute for U.S. program information; various sources for Canadian program information. 1. California has a state-managed electronics recycling/advance disposal fee program that does not include producer responsibility. It also has a separate cell phone EPR law. 2. Deposit system, not generally considered to be EPR. 3. The Alberta electronics system is run by the province and does not include producer responsibility. 4. Although not currently a designated EPR material by Ontario, these materials are currently accepted in the Orange Drop collection program operated by Stewardship Ontario. Reasons and Objectives Cited for EPR A growing number of advocacy groups, government agencies, and certain consumer products companies are promoting EPR. These groups assert that EPR satisfies the following objectives: 3 End-of-life management cost shift Consumers, businesses, and cash-strapped local governments are often not willing or able to incur more cost to achieve higher disposal diversion rates shifting some or all of these costs to producers (and ultimately the consumers of those specific products) can provide more comprehensive and sustainably-funded systems. Cost equitability Under EPR consumers and producers pay end-of-life management costs for the products they consume/produce, rather than spreading the cost burden equally over all tax payers or all rate payers. This is called the polluter pays principle and is considered fair. This also aligns incentives with each group s ability to control product/waste decisions. 3 These reasons and objectives will be compared to EPR program outcomes later in this study to determine if they have been met. 1-4 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

13 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES Pollution reduction For a reduction of pollution in the environment to occur, more products that are problematic must be diverted from improper disposal (generally away from disposal in municipal solid waste landfills or waste-to-energy plants) under an EPR program than under other non-epr approaches. Product/package redesign EPR can send a price signal back to producers, providing a further incentive for them to minimize hazardous components, minimize packaging, and design for longer life, reuse, and/or recycling. However, individual producers may need to physically take back their individual and specific products, or otherwise be provided with different fee levels depending if they redesign products, in order for product or package redesign to occur. Sustainability EPR can contribute to shifting toward the use of renewable resources, longer product life, reduced natural resource consumption, and green jobs. Landfill diversion Landfill space consumption can be minimized by diverting from disposal materials that compose a significant volume of the waste stream. Disposal handling problems Some materials because of their size, shape, or resiliency present handling problems to traditional waste collection and disposal equipment. Management through a different infrastructure can reduce operational difficulties and associated cost. Recycling market development Requirements for producers to physically take and recycle products, or use of producer funds to overcome market barriers, can lead to new or more cost-effective markets for certain materials. Some of these objectives or reasons for EPR apply to certain products but not others. The following table summarizes commonly cited reasons for EPR as they apply to specific products. Product Table 1-2 Common Product-Specific Reasons for EPR EOL Management Cost Shift Cost Equitability Batteries Pollution Reduction Product/Package Redesign Electronics Fluorescent lights (mercury) Mercury containing devices Paint Motor oil/filters Other household hazardous waste Pharmaceuticals Sustainability Landfill Diversion Disposal Handling Problems Tires Recycling Market Development File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 1-5

14 Section 1 Product EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Disposal Handling Problems Carpets Mattresses Packaging Printing & writing paper Beverage containers Toys Plastic bags Small electric items Framework (not product specific) Recycling Market Development We reviewed the U.S. laws for each of the EPR programs to identify the stated objectives. The stated goals and objectives often included the desire for producers to assume cost, assume responsibility for program design/operation, achieve specific diversion targets, provide a certain level of convenience or service, specify certain cost/fee levels, or more generally provide more pollution reduction, redesign of products/packaging, or sustainable use of resources. The following table summarizes the results of our review. Table 1-3 EPR Goals and Objectives Identified in State and Provincial Laws Product EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Disposal Handling Problems Recycling Market Development Batteries California Rechargeable Battery Recycling 100% Florida Rechargeable Batteries Iowa Household Batteries Recycling Maine Dry Cell Batteries Maryland Mercuric Oxide Batteries Every Maryland Rechargeable Batteries Each Minnesota Rechargeable Batteries 90% New Jersey Battery Management New York Rechargeable Batteries Vermont Rechargeable Batteries 1-6 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

15 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES Electronics Product EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign California Cell Phone Recycling 100% Connecticut Covered Electronic Devices Hawaii Electronic Devices Recycling Illinois Electronic Recycling and Reuse 70% Indiana E-waste Recycling 60% Maine Electronic Waste Michigan Electronics Recycling 60% Minnesota Electronics Recycling 80% Missouri Computer Equipment Recovery New Jersey Electronic Waste Recycling New York Electronic Equipment 5 lbs/ person North Carolina Discarded Computer Equip. Oklahoma Computer Equipment Recovery Oregon Electronic Devices Pennsylvania Covered Electronic Devices +2%/yr Rhode Island Electronic Waste South Carolina Electronic Mfgr. Responsibility Texas Computer Equipment Recycling Texas Recovery and Recycling of Televisions Utah Disposal of Electronic Waste Vermont Recycling/Disposal Electronic Waste 6 lbs/ person Virginia Computer Recovery and Recycling Washington Electronic Product Recycling West Virginia Take-back Electronic Devices Wisconsin Electronic Waste Recycling 80% Fluorescent Lights (Mercury) Maine Mercury Containing Lighting Massachusetts Mercury Management 70% Vermont Fluorescent Lamps Washington Product Stewardship Mercury Light Mercury Automobile Switches Arkansas Auto Mercury Switches 90% Illinois Auto Mercury Switch Removal 70% Sustainability Landfill Diversion Disposal Handling Problems Recycling Market Development File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 1-7

16 Section 1 Product EOL Management Cost Shift Cost Equitability Indiana Mercury Switches Pollution Reduction Iowa Auto Mercury Free Recycling 90% Product/Package Redesign Louisiana Auto Mercury Risk Reduction Maine Mercury Products 160 lb Maryland Mercury Switch Removal 90% Massachusetts Mercury Management 90% New Jersey Auto Mercury Switch Removal 90% North Carolina Auto Mercury Switch Removal 90% Rhode Island Mercury Reduction 70% South Carolina Auto Mercury Switch Removal Utah Auto Mercury Switch Removal Vermont Auto Switches Management majority Virginia Auto Mercury Switches Mercury Thermostats Paint California Thermostats Collection Program Illinois Mercury Thermostat Collection 15k Iowa Mercury Added Thermostat Maine Mercury Products (Thermostats) 90 lb Montana Disposal of Mercury Thermostats New Hampshire Mercury-added Thermostats Pennsylvania Mercury Thermostats Rhode Island Mercury Reduction 2,500 Vermont Mercury-added Thermostats 65% California Architectural Paint Program Connecticut Paint Stewardship Program Oregon Paint Stewardship Carpets California Carpet Stewardship Framework British Columbia 75% 75% Maine Manitoba Ontario Quebec Sustainability Landfill Diversion Disposal Handling Problems Recycling Market Development 1-8 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

17 EXTENDED PRODUCER RESPONSIBILITY OBJECTIVES Appendix A provides brief bulletized excerpts of the goals and objectives summarized in Table 1-3. It also provides website links where more information about the different programs can be viewed. Voluntary Product Stewardship In addition to the mandated EPR programs listed earlier in this report section, there are a number of voluntary product stewardship programs operating in the United States, including: Agricultural Chemical Recycling Council agricultural chemical bottles and barrels. Carpet America Recovery Effort carpet. ecycling Leadership Initiative provides consolidated information on electronics recycling opportunities offered by members of the Consumer Electronics Association, End of Life Vehicles Solutions Corporation mercury switches and high voltage (hybrid/ev) batteries. PaintCare architectural paint. Rechargeable Battery Recycling Corporation (RBRC) doing business as Call2recycle rechargeable batteries including Nickel Cadmium (Ni-Cd), Nickel Metal Hydride (Ni-MH), Nickel Zinc (Ni-Zn), Lithium Ion (Li-Ion), Small Sealed Lead Acid (SSLA/Pb). Thermostat Recycling Corporation mercury thermostats. Various individual manufacturer/retailer efforts. In some cases, the voluntary product stewardship programs operate both their national voluntary programs and the state-specific EPR programs for the products they represent. File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 1-9

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19 Section 2 EPR GOALS, OBJECTIVES, AND RESULTS Section 1 presented the stated objectives of EPR laws for each covered product (for U.S. laws) and of the framework EPR laws/regulations for those Canadian provinces with framework authorization. These objectives often include the desire for producers to assume cost, assume responsibility for program design/operation, achieve specific diversion targets, provide a certain level of convenience or service, specify financial incentives, or reduce environmental impacts in general. This section compares objectives for EPR as outlined in state and provincial policy documents to reported performance and cost data for each EPR program, to the extent that data was available. Because of the large number of EPR programs in North America (over 120), the analysis focused only on U.S. EPR programs and comparable Canadian EPR programs that are operating under a framework EPR regulatory environment. The analysis found that EPR has had mixed results for the products and programs evaluated by this study. Summary of EPR Objectives and Outcomes Many EPR programs have only recently been implemented or are still in the process of being implemented and so do not have performance data that have been compiled and released. For example, in the United States, 30 percent of the EPR programs are so new that they have not yet released first-year program data. Table 2-1 summarizes the EPR objectives and results for programs that were active in Because of the timing of this project, 2011 program data were not yet available for analysis. The table presents information for U.S. programs first, followed by information on Canadian programs for framework EPR provinces for the same products covered by U.S. programs. File: / Producer Responsibility Eval

20 Section 2 Table 2-1 Summary of EPR Objectives and Program Outcomes EPR Objectives Program Outcomes Product and EPR Law Batteries California Rechargeable Battery Recycling Florida Rechargeable Batteries Iowa Household Batteries Recycling Maine Dry Cell Batteries Maryland Mercuric Oxide Batteries Maryland Rechargeable Batteries EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost 100% Not reported by Call2Recycle Not reported by Call2Recycle Not reported by Call2Recycle Not reported by Call2Recycle Every Not reported by Call2Recycle Each Not reported by Call2Recycle EPR Diversion Quantity 7.1 million lbs. overall lbs/person 373,802 lbs lbs/person Not publicly reported 1.84 tons State Planning Office estimate lbs/person Not publicly reported Not publicly reported Comments Dept. of Toxic Substances Control (DTSC) arrived at these estimates from data voluntarily submitted to DTSC by the major battery recyclers in California. Call2Recycle reported 932,882 lbs. from California for Nearly 30% of rechargeable nickel-cadmium batteries discarded annually in Florida are recycled through RBRC collection sites. 3 There is no requirement that data on collection or disposal be reported. There are no readily available Maine-specific data on rechargeable batteries. manufacturers reduce or eliminate the use of toxic constituents, exemplified by a 98 percent reduction in the use of mercury State program website link to Call2Recycle State program website link to Call2Recycle 2-2 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

21 EPR GOALS, OBJECTIVES, AND RESULTS EPR Objectives Program Outcomes Product and EPR Law Minnesota Rechargeable Batteries New Jersey Battery Management Vermont Rechargeable Batteries Electronics California Cell Phone Recycling Hawaii Electronic Devices Recycling Illinois Electronic Recycling and Reuse EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost 90% Not reported by Call2Recycle Not reported by Call2Recycle 1992 Not reported by Call2Recycle 100% year year 1 70% year 1 EPR Diversion Quantity Not publicly reported 111,907 lbs lbs/person Not publicly reported Unknown 21% DTSC estimate (4.9 lbs/person) 4 Unknown registration fees (govt. administration) totaled $0.29 million for 2011 and 6.8 cents/lb. for Unknown registration fees (govt. administration) totaled $0.26 million 6 or 0.9 cents/lb. 3,235,432 lbs. (2.38 lbs/person) 30,183,168 lbs. (2.35 lbs/person) Comments State program website link to Call2Recycle State program website link to Call2Recycle No legal requirement to report cell phone sales or recycling; recycling rate is based on data collected and derived by California DTSC. Recovery programs are individually implemented by retailers. TVs added in 2011 to existing computer electronic devices program. Program cost data reporting is not required and programs are individually implemented by producers goal was 31,336,903 lbs. and 2011 goal is 28,156,281 lbs. Expanded list of products in Recyclers report quantity figures on manufacturers behalf (cost not reported) File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 2-3

22 Section 2 Product and EPR Law Maine Electronic Waste Minnesota Electronics Recycling EOL Management Cost Shift Cost Equitability EPR Objectives Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date year 5 80% year 4 Program Outcomes EPR Program Cost 33cents/lb paid by manufacturers (2009, excludes collection costs but includes transportation and recycling) plus annual registration (govt. administration) fees of $0.20 million 7 or 3.7 cents/lb. Unknown registration fees (govt. administration) totaled $0.16 million or 0.5 cents/lb.; in addition, $83,720 obligation fees were paid to state (in lieu of producers meeting recycling obligation). EPR Diversion Quantity 5,338,287 lbs. (4.02 lbs/person) 588,978 lbs. lead ( assume 5 lbs. of lead per unit collected, 0.11 lbs. Pb/lb e-waste) lbs. covered electronic devices recycled (6.2 lbs/person) Comments NERC Environmental Benefits Calculator reports 87,445 million BTUs of energy and 1,248 metric ton equivalent CO2 savings for 2008 recycling quantities... television manufacturers have focused on creating flat-panel televisions overtaking CRT models as their cost and space reductions entice consumers [note: this trend results in less weight available for recycling in the future since lead is heavy] 26.9 million lbs. of video display devices were sold for a recycling rate over 100%, in part because heavy lead-glass CRTs were replaced with lighter flat screen devices. It is also possible that other electronic devices were reported in the numerator, whereas the denominator only included covered electronic devices. Reporting of overall system costs not required the perpound cost for collecting and processing waste electronics is generally lower, and some instances dramatically lower, than what was in place prior to the Act s implementation [the Act has also resulted in] expanded collection infrastructure significant increase in the volume of waste electronics collected expanded economic development activity in the state SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

23 EPR GOALS, OBJECTIVES, AND RESULTS Product and EPR Law North Carolina Discarded Computer Equip. Oklahoma Computer Equipment Recovery Oregon Electronic Devices Rhode Island Electronic Waste Texas Computer Equipment Recycling EOL Management Cost Shift Cost Equitability EPR Objectives Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date year year year year year 2 Program Outcomes EPR Program Cost Unknown Unknown registration fees (govt. administration) are over 2.5 cents/lb. 11 Unknown, private program costs are not available; Dept. of Environmental Quality had both outreach and administrative costs of $480,000 in FY10 (projected to decline to $346,763 in FY11 (2.0 cents/lb.) Unknown registration fees (govt. administration) are estimated by SAIC at approximately 8 cents/lb. 13 Unknown no registration fees or cost reporting EPR Diversion Quantity 9,148,000 lbs. (0.10 lbs/person) per Electronics Take-back Coalition 2,554,632 lbs. (0.68 lbs/person) 24,149,774 lbs. (6.31 lbs/person) 2.1 million pounds of lead 12 2,823,369 lbs. (2.68 lbs./person) 24,370,894 lbs. (0.97 lbs/person) Comments Producers implement individual recovery programs and can elect to provide one of three levels of recycling plan service. Annual registration fees vary depending on the level of service. 10 Producers implement individual recovery programs. Collection target set by Oregon DEQ of 3.3 pounds/person. Manufacturers may operate group or independent programs, or they may participate in the state program that is operated by a state contractor. 8,479,780 lbs. were collected through the state contractor program, which partners with municipal and non-profit collection points). More than 25,000 units have been reused in Oregon during the initial nine months of the Oregon E-Cycles program. 12 Manufacturers must either run their own takeback program or participate in a state run takeback program run by the RI Resource Recovery Corporation (RIRRC). Producers implement individual recovery programs File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 2-5

24 Section 2 EPR Objectives Program Outcomes Product and EPR Law EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost EPR Diversion Quantity Comments Virginia Computer Recovery and Recycling year 2 Unknown no registration fees or cost reporting 4,439,446 lbs. (0.56 lbs/person) Producers implement individual recovery programs Washington Electronic Product Recycling year cents/lb. for Washington Materials Management and Financing Authority, which includes 3.5% administrative cost, plus registration fees paid to WA Ecology of $0.36 million (0.9 cents per pound). 42,193,038 lbs. (6.18 lbs/person) 3.7 million pounds of lead 12 The consolidation of electronics recycling activities into state-wide systems has created program efficiencies relative to the cost of collection, transportation and recycling with operating costs well below prices charged to scattered local governments and private programs before E-Cycle implementation some of this pricing reduction is likely due to increased program efficiencies (e.g., a consolidated administrative structure) and some is likely due to the stronger pricing power that comes with larger, consolidated purchases of recycling and related services the Washington program allows collectors to resell or donate equipment for reuse, but does not track reuse activities. 12 West Virginia Takeback Electronic Devices year 2 Unknown registration fees fund govt. administration and program grants of over 28 cents/lb 14 full public and private program costs are not known. 825,000 lbs. (0.45 lbs/person) 2-6 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

25 EPR GOALS, OBJECTIVES, AND RESULTS EPR Objectives Program Outcomes Product and EPR Law Wisconsin Electronic Waste Recycling Fluorescent Lights (Mercury) Massachusetts Mercury Management Mercury Switches (Auto) Arkansas Auto Mercury Switches Illinois Auto Mercury Switch Removal EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date 80% year 2 70% 2011 EPR Program Cost Unknown registration fees (govt. administration) are $415,000 (1.2 cents/lb.) 15 and do not include penalties for failing to meet targets or program operational costs EPR Diversion Quantity 35,149,909 lbs. (6.18 lbs/person) Comments Target of 29 million lbs. Recycled quantity includes 2,616,090 lbs. by unregistered recyclers (subsequently registered in 2012) Unknown 33.8% Municipal and private recovery programs. Recycling targets were 40% by end of 2009 and 50% by end of Failure to achieve 2009 goal means Mass. DEP will collect penalties from industry of up to $1 million to go to grants to municipalities. 90% Bounty of $5/switch to recycler $1/switch to ADEQ plus collection and recycling costs 70% Bounty of $2/switch, $6/ABS to recycler plus collection and recycling costs 6,208 switches lbs. Hg 17% per ELVS 47,137 switches 27% per ELVS File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 2-7

26 Section 2 EPR Objectives Program Outcomes Product and EPR Law Indiana Mercury Switches Iowa Auto Mercury Free Recycling Louisiana Auto Mercury Risk Reduction Maine Mercury Products Maryland Mercury Switch Removal Massachusetts Mercury Management EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date 2007 (est.) EPR Data Date EPR Program Cost 2010 Shared cost state pays bounty of $3/switch, $5/ABS to recycler; industry pays collection and recycling costs 90% Bounty of $5/switch paid to recycler plus collection and recycling costs Unknown collection and recycling costs 90 lb Bounty of $4/switch paid to recycler plus collection and recycling costs 90% year 1 Bounty of $4.00 per Hg light switch, $6.00 per Hg antilock braking system (ABS) unit, $1 to MD DEP; plus collection and recycling costs 90% Bounty of $3 per switch plus collection and recycling costs EPR Diversion Quantity 28,119 switches 26% per ELVS 14,733 switches 32.4 lbs. Hg 23% per ELVS 549 switches 1% per ELVS 5,685 switches 27% per state recovery data and ELVS generation data 6,494 switches lbs. from to % per ELVS 15,178 switches 23% per ELVS Comments Before program not managed by or reported by ELVS (some independent plans, plus major autos through Wesco). Goal is double the number of available switches per ELVS model. Since 2003 inception through 2010, program has collected 50,969 switches (112 lbs. Hg). Program is somewhat new and may not yet grown to higher steady state levels DEP letter of failure to achieve objectives and requirement of new plan submission 2-8 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

27 EPR GOALS, OBJECTIVES, AND RESULTS EPR Objectives Program Outcomes Product and EPR Law New Jersey Auto Mercury Switch Removal North Carolina Auto Mercury Switch Removal Rhode Island Mercury Reduction South Carolina Auto Mercury Switch Removal Utah Auto Mercury Switch Removal Vermont Auto Switches Management Virginia Auto Mercury Switches EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost 90% Bounty of $2.00 per switch, $0.25 per to NJ DEP plus collection and recycling costs 90% of national average recovery rate Shared cost DENR pays program admin costs plus bounty of $5.00 per switch; mfgrs. pay recycling and freight cost 70% Bounty of $5.00 per switch, $1.00 to the state plus collection and recycling costs Unknown collection and recycling costs Bounty of $5/switch plus collection and recycling costs majority Unknown collection and recycling costs Unknown collection and recycling costs EPR Diversion Quantity 9,850 switches 9% per ELVS 97,535 switches 102%per ELVS 3,597 switches per ELVS (36%) 3,321 switches per ELVS (7%) 7,117 switches per ELVS (27%) 366 switches per ELVS (5%) 11,822 switches per ELVS (14%) Comments $2.50 tax credit for each switch collected and submitted to reduce state taxes. No bounty paid since summer 2009 after national voluntary incentive ran out recycling fell significantly since then File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 2-9

28 Section 2 EPR Objectives Program Outcomes Product and EPR Law Mercury Thermostats California Thermostats Collection Program Iowa Mercury Added Thermostat Maine Mercury Products Montana Disposal of Mercury Thermostats New Hampshire Mercury-added Thermostats Pennsylvania Mercury Thermostats Vermont Mercuryadded Thermostats EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date year year 1 EPR Program Cost Unknown collection and recycling costs Unknown collection and recycling costs 160 lb $5/t-stat bounty began in 2009 plus unknown collection and recycling costs Unknown collection and recycling costs Unknown collection and recycling costs year 1 65% year 2 Unknown collection and recycling costs $5 bounty beginning in 2009 plus unknown collection and recycling costs EPR Diversion Quantity 188 lbs. (20,027 t-stat est.) t-stats/10,000 people 2,983 t-stats by TRC ( lbs., 12,306 g); 5 t-stats by EWC Controls (12 g.) 9.81 t-stats/10,000 people 6,523 t-stats of est. 27,200 per year (24%) t- stats/10,000 people lbs Hg Unknown 790 t-stats per TRC, 6.00 t-stats/10,000 people 5.2 lbs. Hg. 9,500 t-stats per TRC, exactly meeting the year 1 goal;99 lbs. Hg 3,349 t-stats per TRC, per 10,000 people Comments ,542 thermostats (partial year), up 7% from 2008 pre-law level under voluntary national program (7,059 thermostats) Disagreement with industry on available thermostats, so no percent reported Target is approximately 85% of thermostats Recovery is up 45% from 2008 voluntary TRC program; estimate of available thermostats is between 8,000-17,000/yr Up 30% from the previous voluntary TRC program. Up significantly from 1,890 in 2009, 1,665 in 2008, and 1,367 in SAIC Energy, Environment & Infrastructure, LLC PMA Final Report

29 EPR GOALS, OBJECTIVES, AND RESULTS EPR Objectives Program Outcomes Product and EPR Law EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost EPR Diversion Quantity Comments Paint Oregon Paint Stewardship year 1 $7.03/ gal $3.3 million total program cost, incl. administrative costs of 17%, which includes payments to Oregon DEQ for program oversight. 469,665 gal and 4,696,650 lbs. 64% collection rate estimate (at least a 3% increase over pre-epr recovery levels) 19 In year 1, 39% recycled, 37% fuel, 21% landfill ( biodegradation ), 3% reuse. 19 No reduction in waste paint generation 20 Selected Canadian Provinces/Products Covered by EPR Batteries British Columbia (half year) Not available Half year: 95,000 kg primary (94% of plan target); 26,000 kg of rechargeable (104% of plan target) Primary and rechargeable batteries for cordless and cellular phones and personal audio players. Phased coverage for batteries from other products in 2011 and File: / Producer Responsibility Eval SAIC Energy, Environment & Infrastructure, LLC 2-11

30 Section 2 EPR Objectives Program Outcomes Product and EPR Law EOL Management Cost Shift Cost Equitability Pollution Reduction Product/Package Redesign Sustainability Landfill Diversion Collection Start Date EPR Data Date EPR Program Cost EPR Diversion Quantity Comments Ontario singleuse 2010 Stewardship Ontario CAN$3,188,042 (primary batteries, ~US$3,700 per ton) Call2Recycle cost not disclosed Stewardship Ontario - 762,000 kg primary batteries Call2Recycle - 75,093 kg primary batteries and 139,291 kg rechargeable batteries Manufacturers have voluntarily funded a rechargeable battery collection program in Ontario through Call2Recycle since at least In July of 2008, Stewardship Ontario (SO) began operating an EPR program for non-rechargeable (primary) batteries. In July of 2010 battery EPR was expanded to rechargeable batteries. From July 1, 2010 to March 31, 2011 Call2Recycle was the battery service provider to SO, collecting both types of batteries. Currently, SO only collects primary batteries and Call2Recycle only collects rechargeable batteries. Electronics British Columbia Phased (8-2007) 2009 CAN$1,141/tonne (~US 59 cents/lb.) 14,017,680 kg televisions and computers (6.76 lbs/person) Phased approach with televisions and computers added in 2007 and cell phones and consumer audio equipment July Ontario Phased (4-2009) to CAN$1,634/tonne (~US 73 cents/lb.) 33,847 tonnes collected (5.58 lbs/person) Phased approach with televisions and computers collected beginning April 2009 and cell phones and audio and video equipment April Program targets were 46,617 tons collected and of that, 37,294 tons recycled. Packaging and Printed Paper 2-12 SAIC Energy, Environment & Infrastructure, LLC PMA Final Report