TL: INDUSTRY'S ENVIRONMENTAL RESPONSIBILITY: BEYOND THE POINT TL: INDUSTRY'S ENVIRONMENTAL RESPONSIBILITY: BEYOND THE POINT OF SALE SO: Greenpeace Quebec (GP) DT: August, 1996 Keywords: environment toxics chlorine waste business quebec canada legal / TRUE WASTE REDUCTION THROUGH EXTENDED PRODUCER RESPONSIBILITY: A CHALLENGE FOR QUEBEC A brief submitted to the BAPE (Bureau d'audiences publiques sur l'environnement) Commission of Enquiry on Solid Waste Management A project of Greenpeace Canada Charitable Foundation GREENPEACE QUEBEC August 1996 researched and written by Beverley Thorpe, Clean Production Action edited and with contributions by Matthew Bramley, Greenpeace Quebec version, October 11, 1996 printed on 100% post-consumer recycled paper with no added chlorine EXECUTIVE SUMMARY The government of Quebec has set a target of 50% waste reduction by the year 2000 (relative to 1988). It proposes to achieve this through the sharing of responsibility between the public and private sectors, producers and consumers. But while the government's proposals cover the management of certain categories of waste, they do not consider the design of products and choice of materials which are at the source of the waste problem. Materials policy, not waste management policy Policymakers in several European countries have, in contrast, concluded that the bulk of responsibility for the waste problem must be carried by producers. This approach is known as Extended Producer Responsibility (EPR). Its consequence is that measures to achieve waste reduction become part of an overall materials policy focussing on the entire life cycles of products and their constituent materials. Sustainable material use will only be achieved by replacing current linear materials flows - which end in waste mountains - by closed materials cycles. A wide variety of tools are available to achieve more efficient and safer materials use, including voluntary or mandatory product take-back schemes, deposit-refund schemes, restrictions or bans on the use and/or disposal of certain materials, mandatory disclosure of environmental information about products and processes, eco-labelling, government procurement of environmentally sensitive products, etc. Most of these represent ways to implement EPR. The tool: Extended Producer Responsibility EPR is the application of the polluter-pays principle to products. In concrete terms, EPR means that producers (which may include importers and retailers) must participate directly in the management of their products once the latter reach the end of their useful life. Typically they are required to take back their end-of-life products and re-use and recycle them in accordance with pre-set targets. The benefits are clear: according to the head of priority waste stream planning at the Netherlands environment ministry, there is "no doubt at all that... EPR schemes are having a clearly positive environmental impact". EPR is not just a theoretical concept. It has already been implemented for some products and is at an advanced stage of planning for others in several countries, most notably Germany, the Netherlands, and Sweden. In some cases product take-back is required by law; in others it is voluntary but backed up by legislation. Several draft laws are also being circulated by government agencies in these countries. Typically industry is anticipating the draft legislation by setting up its own voluntary EPR schemes. EPR in Europe Germany has had a statutory take-back scheme for packaging since 1991. It requires recovery rates in 1996 of 64-72% for glass, paper, plastic, aluminium and other drinks containers. Since 1992 the Environment Ministry has also been promoting the mandatory take-back of scrapped cars. The draft law would require 100% of steel and 50% of plastics to be recycled by the year 2000. German car manufacturers are already working hard to meet these goals, and are modeling their take-back operation along the lines of the system already in place for packaging. In 1994 Germany enacted a new Biocycle Law which will take effect in October 1996. The law rests on the principles of ecological design of products and EPR, among others. Currently the Netherlands has EPR for car scrap, packaging, batteries, tyres, plastic construction materials and agricultural plastics, implemented through a combination of laws and voluntary agreements. The Netherlands Packaging Covenant aims to recycle a minimum of 60% of used packaging which cannot be re-used, including up to 75% recycling of plastics. Blister packaging has "more or less disappeared". Under the Auto-Recycling Nederland scheme, 75% of scrapped cars are dismantled by the car industry. It is expected that within a few years this figure will increase to more than 95%. In 1993 Sweden enacted an Ecocycle Bill which sets out a national environmental policy based on closing materials cycles. EPR was one of the most important new concepts introduced in the bill. An Ecocycle Commission was appointed to define ways to implement the goals set by the bill. The Commission and the Environmental Protection Agency (EPA) have drafted ordinances for several product streams, and set goals including an 80% reduction in the landfilling of tyres by 1998, and a limit of 5% on the proportion (by weight) of car scrap than can be disposed of by 2015. Take-back legislation for cars should enter into force on January 1, 1997. It will apply to vehicles marketed before the introduction of the new system and includes mandatory ecolabelling. Swedish industry is on the whole endorsing the implementation of EPR. The need to phase out PVC plastic EPR goes hand-in-hand with the phasing out of hazardous materials, another area in which Sweden has been a leader. One of the most widespread such materials is PVC, the world's second most common plastic. PVC's production and disposal by incineration are a primary source of dioxin, one of the most toxic substances known to science. Recycling of PVC is impractical and the plasticizer and heavy metal additives in PVC leach out in landfills. These toxic additives are also released during normal use of PVC products, such as window blinds that release lead-containing dust on exposure to sunlight. According to the Swedish Environment Minister Anna Lindh, "the question is not whether to phase out PVC, but how...". Take-back of electrical and electronic equipment in Europe Electrical and electronic equipment (EEE) provides a good example of products containing a wide variety of materials, many of which pose serious environmental problems. All three of the countries cited above have draft legislation for producer take-back of EEE. The Dutch and German drafts place almost full responsibility for recycling on manufacturers and importers, who will be required to establish collection systems. The Dutch proposal sets out a product take-back goal of 100% by the year 2000 with recycling targets as high as 95% for specific materials. The Swedish proposal plans to recover 85% of all discarded EEE by the year 2000. In the longer term, the aim is to minimise all environmental impacts from these products during their entire life cycle. The Swedish approach to EEE has been set out in detail by the EPA; Greenpeace proposes it to the government of Quebec as a model for EPR policymaking. Greenpeace's recommendations for Quebec Waste generation in Quebec is out of control. The proposals made by the government of Quebec to remedy the situation are timid (only 50% waste reduction relative to 1988) and vague. The government also apparently lacks any vision of what will happen more than four years in the future. The Commission of Enquiry must reject definitively this unimaginative approach. It must rise instead to the challenge of formulating a new, ambitious, product-focussed materials policy for Quebec. Greenpeace is making 26 detailed recommendations for how to bring this about. They are intended to remedy Quebec's lack of the necessary legislative and institutional structure for materials policy design and implementation; to achieve more efficient material use; and to achieve cleaner material use. In particular: A) Quebec should be given immediately its own Ecocycle Commission, an independent policy-making body with the mandate to study material flows and make recommendations to reduce their environmental and health impacts. To give legislative definition to the Commission, a parliamentary committee should be set up to propose legislation along the lines of the Swedish Ecocycle Bill. B) The government of Quebec must adopt an agressive timetable for the reduction of waste going to "disposal" extending beyond the year 2000, including 80% reduction by 2010 relative to 1988. C) Waste reduction should be enforced by legislated bans on landfilling: - re-usable and recyclable materials within 2 years; - putrescible materials within 4 years; and by making illegal the inclusion by householders of recyclables and hazardous household waste (HHW) in regular garbage within 2 years. Verification should be carried out by random checks. D) Mandatory, local producer and/or retailer take-back programs should be introduced for tires, scrapped cars, electrical and electronic equipment and packaging, following the European models. E) The government of Quebec should prohibit all new incinerators, including hospital waste and sewage sludge incinerators, industrial incinerators and hidden forms of incineration such as are carried out in cement kilns and plants that recycle metals contaminated by plastic and oils. The incinerator at Lvis must be closed immediately and the government must close within 4 years all other waste incinerators of all types. F) The government of Quebec should introduce mandatory toxics labelling legislation along the lines of California's Proposition 65, to ensure that any product containing substances that are known to be carcinogenic, neurotoxic, bioaccumulative or hormonally active be labelled as such. G) Complete listing of products' ingredients and recycled content should be made mandatory in Quebec within 4 years. The labelling of paper and other products bleached with chlorine-containing compounds, and the labelling of paper with the percentage post-consumer recycled content should be made mandatory immediately. H) The government of Quebec must ban immediately the use of PVC plastic in food packaging; stop using it in new public construction projects; and set up a timetable for the phaseout of all other uses of PVC as follows: - all packaging material and other short-lived goods containing PVC including medical supplies within 2 years; - all other PVC goods such as toys, wallpaper, upholstery, flooring, pipes, window frames and siding within 4 years. TABLE OF CONTENTS INTRODUCTION 1. WHAT IS EXTENDED PRODUCER RESPONSIBILITY (EPR)? GOALS OF EXTENDED PRODUCER RESPONSIBILITY (BOX) 2. WASTE MANAGEMENT IS ONLY ONE PART OF THE MATERIALS CHAIN Less resource use by a factor of ten THE UNITED NATIONS AND CLEAN PRODUCTION (BOX) 3. EUROPEAN PROGRESS ON IMPLEMENTING EPR The Netherlands Germany Sweden 4. SUMMARY OF TOOLS TO ACHIEVE MORE EFFICIENT MATERIALS USE 4.1 Corporate or industry-wide product stewardship programs 4.2 Voluntary take-back or buy-back schemes Example: Netherlands take-back of packaging and car scrap 4.3 Leasing schemes 4.4 Deposit-refund schemes 4.5 Product taxes to fund waste management systems 4.6 Mandatory take-back requirements Focus: Mandatory car scrap take-back in Sweden 4.7 Incentives for de-materialisation or less resource use 4.8 Disposal bans 5. SUMMARY OF TOOLS TO ACHIEVE CLEANER MATERIAL USE 5.1 Materials or product taxes 5.2 Materials restrictions or prohibitions 5.3 Environmental management and auditing systems 5.4 Mandatory disclosure of environmental information 5.5 Eco-labelling 5.6 Government subsidies and tax credits 5.7 Government and institutional procurement of environmentally sensitive products and materials 6. ELECTRICAL AND ELECTRONIC EQUIPMENT EPR - EUROPEAN OVERVIEW The Netherlands: objectives for the electronic waste stream Germany: Electronic Waste Ordinance Other countries 7. IMPLEMENTING EPR: SWEDEN'S APPROACH TO ELECTRICAL AND ELECTRONIC EQUIPMENT TAKE-BACK LEGISLATION - A CASE STUDY 7.1 Formulation of environmental objectives 7.2 Description of the product area 7.3 Description of the environmental problems associated with the products 7.4 Environmental problems at the end-of-life stage The problem with incineration Accident potential at waste sites The problem with landfilling The problem with hazardous recycling 7.5 Description of systems and facilities currently available for separate waste management of the products 7.6 Progress in other countries on environmentally sensitive scrapping and product development 7.7 Incentives for cleaner product development 7.8 Identify what government, industry and consumers can do 7.9 Implementing control over current and future products 7.10 Assessment of the costs and benefits involved in implementing the proposals 8. CONCLUSIONS AND RECOMMENDATIONS 8.1 The problem 8.2 The solution: EPR 8.3 Materials policy, not waste management policy Legislative and institutional structure More efficient material use Cleaner material use APPENDIX. PVC: A MATERIAL WHOSE DAYS SEEM NUMBERED PVC production and disposal: a primary source of dioxin The problems with recycling and landfilling PVC use: a range of emerging hazards "The question is not whether to phase out PVC, but how..." REFERENCES Abbreviations LIST OF FIGURES 1. Extension of Producer Responsibility 2. Structures of industrial and sustainable economies compared 3. Take-back scheme proposed by the Netherlands large domestic appliances industry INTRODUCTION The government of Quebec has set a target of 50% waste reduction by the year 2000 (relative to 1988), waste being defined as any material or object that is put out for disposal by Quebec households and similar materials generated by industry, commerce and institutions [1]. The principles of waste management set out by the government of Quebec include Shared Responsibility: "All those involved, whether in the public or the private sector, producers or consumers, must assume their share of responsibility in waste management. Applying the rule that polluters pay for the damage they cause to the environment will encourage this responsibility. And for effective action, all involved must have the means and the authority to act." [2] The Quebec government proposes a variety of ways to achieve waste reduction [3]. However, although mention is made of shared responsibility, there is no direct strategy of producer responsibility for products in general. Rather the scope of the government's proposals covers household garbage, organic green waste, tires and dry material (building rubble). The European Union (EU) and some industries have responded to the problem of increasingly scarce landfill sites and the mounting evidence of incineration problems by focussing on the life cycle of material flows and Extended Producer Responsibility (EPR) for products. Producer responsibility for electrical and electronic equipment will be used here as a case study. To enhance its future industrial competitiveness and benefit from the employment and environmental advantages of EPR planning, we recommend that Quebec follow the European lead and require the first regional strategy for product take- back in North America. Provinces have the jurisdication to deal with non-hazardous waste materials and Quebec should seize this opportunity to introduce progressive product management strategies. This will be the most efficient way to achieve true waste reduction and ensure competitiveness for Quebec in the new expanding market of ecologically designed products. 1. WHAT IS EXTENDED PRODUCER RESPONSIBILITY (EPR)? Extended Producer Reponsibility (EPR) is the principle that manufacturers of products bear a degree of responsibility for the environmental impacts of their products throughout the products' life cycles. This includes: a) the upstream impacts inherent in the selection of raw materials and energy; b) impacts from the production process itself; and c) downstream impacts from the use and disposal of the products at the end of their useful consumer life. The aim of Extended Producer Responsibility is to ensure environmental protection by proper materials management throughout products' life cycles. From this, several goals are established, the two most fundamental of which are: - Product design for waste reduction throughout the life cycle; and - Product design for cleaner, safer material use. This is quite different from current waste management because it shifts the financial and material responsibility away from local authorities back to the producer. By incorporating the true cost of waste management at the product design stage it becomes financially more attractive for producers to design products that are easier to disassemble, re-use and recycle. Only this will ensure safe and easy handling of materials at the end of their consumer lifespan. It is also anticipated that smaller quantities of materials will be used and that materials will be safer and more energy efficient. The result is a reduction in resource use and waste generation. GOALS OF EXTENDED PRODUCER RESPONSIBILITY [box] - overall waste prevention; - the use of non toxic materials and processes; - the development of closed materials cycles; - the development of more durable products; - the development of more re-usable and recyclable products; - increased re-use, recycling and composting; - regionalisation of production, consumption and materials management; - the transfer of waste management costs for used products onto producers, consistent with the polluter pays principle. Most of these objectives can be factored into product design which is the most crucial step in determining the nature and quantity of resource use and pollution emissions throughout products' life cycles. [figure 1] 2. WASTE MANAGEMENT IS ONLY ONE PART OF THE MATERIALS CHAIN Waste management must be viewed as only one stage in the materials chain. Material choice in product design dictates what happens to the material after first consumer use. A major reduction in waste can be achieved by better product design and choice of materials that are eco-sensitive. Designing products within ecological principles leads to less consumption of materials. In nature nothing becomes waste: byproducts of renewable production systems become part of the cycle of continual uptake and use. The natural system is dynamic, complex and energy efficient. Human production systems rely on natural organic, inorganic and synthetic material use. Bio-based, organic materials such as paper and timber can be re-used, sometimes for a long period of time, and then recycled or composted. But production systems that use bio-based materials will be sustainable only if extraction rates do not exceed natural regeneration rates and biodiversity is maintained. Materials made of natural inorganic materials such as building stones, bricks, cement, concrete, clay, glass and metals can also be used for long periods thereby utilizing the full value of the energy input that was used in manufacturing the product. These, too, can be re-used at the end of their first consumer lifespan (e.g., refillable bottles) as well as eventually recycled. The extraction of inorganic natural material does, however, pose problems. Every year we globally extract 50 billion tonnes of minerals from the earth's crust. This means that the world's population now consumes an average of 10 tonnes per person per year of mineral resources and that we remove and redistribute more than three times the natural sedimentation of all the world's rivers [4]. The resulting relocation and dispersal of metals via extraction, smelting, manufacturing processes, product use and disposal has created widescale contamination by some particularly harmful heavy metals such as cadmium, mercury and lead. To achieve sustainable metal use, the current on-going extraction of finite mineral resources must be reduced and materials conserved by closed loop systems that prevent emissions of toxic substances such as heavy metals into the wider environment. In [Figure 2] essence this means a dramatic drop in consumption of resources and a more efficient production system based on less material use and the choice of safer materials. Synthetic materials such as plastics, other polymers and fibers, and halogenated compounds - particularly organochlorines -, have increasingly been used in manufacturing processes since the 1940s, based on the unsustainable use of petroleum. Many of these synthetic materials are complex materials that do not easily degrade in the ecosystem and which directly harm living systems because of their global dispersion, persistence and ability to bioaccumulate. Many organochlorine compounds are now targetted for priority elimination in international fora such as the North Sea Ministers' Conference, the Oslo-Paris Convention, and the United Nations agencies UNEP and UNECE [5,6]. Just as PCBs and DDT - two notorious organochlorines - were banned in most industrial countries in the 1970s, the United Nations Global Program of Action on Persistent Organic Pollutants [7], agreed to by 110 countries in 1995, has now targetted dioxin as one of twelve priority compounds to be eliminated because of its ability at minute doses to damage the reproductive system and promote cancer [8]. Dioxin is not intentionally produced. Rather it is generated in a vast range of situations where organochlorines are manufactured, used and/or disposed of. It is now advocated by many that safer synthetic materials be produced using the criteria of natural biological processes. This field of biomimetics, (mimicking biological structures) or "green chemistry" will produce renewable polymer structures that are produced in a more energy efficient way [9]. Biomimetic polymer use should enable safer, more efficient recycling systems without the current problems posed by too many types of plastic mixes. Pertinent to all types of material production is the need for cleaner forms of energy production and an increase in energy efficiency. This can only be achieved via the rapid transition to renewable energy sources, such as solar and wind, for power generation and transportation. In the interim products can be designed with better energy efficiency as well as cleaner material use. Less resource use by a factor of ten The magnitude of the challenge facing us over the next 50 years has been aptly referred to by the Dutch as "the jump". Up to now, technologies have only been able to increase their environmental efficiencies by factors of two to five in reduced materials and energy consumption. In this regard it is stated that "technology will not save us" [10]. Given projections of global population growth and depletion rates of finite resources, the environmental efficiencies of future practices will have to increase by factors of 10-50 by the year 2040 [11]. To this end we need a redesign of material use by society as a whole as well as better product design. Analyses done in Germany indicate a need to improve the resource productivity of Western style economies by an average factor of 10 [12]. Research is now focussing on measuring the efficiencies of material use and the benefits of regionalisation for production and consumption patterns [13]. Many of these criteria are embodied in the concept of Clean Production (see box). THE UNITED NATIONS AND CLEAN PRODUCTION [box] The United Nations Environment Program (UNEP)'s Cleaner Production Programme was established in 1990 as part of its Industry and Environment Office in Paris. The definition of Cleaner Production used by UNEP is: "...the continuous application of an integrated preventive environmental strategy to processes and products to reduce risks to humans and the environment. For production processes cleaner production includes conserving raw materials and energy, eliminating toxic raw materials and reducing the quantity and toxicity of all emissions and wastes before they leave a process. For products the strategy focusses on reducing impacts through the entire life cycle of the product, from raw material extraction to the ultimate disposal of the product. Cleaner Production is achieved by applying know-how, by improving technology, and/or by changing attitudes. How is Cleaner Production different?... Much of the current thinking about environmental impacts focuses on what to do with wastes and emissons after they have been created. The goal of Cleaner Production is to not generate waste in the first place. Why is Cleaner Production important?... In the long run, Cleaner Production is the most cost-effective way to operate processes and to develop and produce products. The costs of wastes and emissions in addition to negative environmental and health impacts can be avoided by applying the cleaner production concept from the beginning." [14] 3. EUROPEAN PROGRESS ON IMPLEMENTING EPR Since the first real producer responsibility scheme was enacted in Germany in 1991, EPR has spread across industrialized countries, industry sectors, product categories and waste streams. EPR has been enacted or is under serious consideration in Austria, Belgium, Denmark, France, Germany, the Netherlands, Sweden, Switzerland and the UK. Developments are also underway in Japan, Korea, and Taiwan. European progress on developing EPR for electrical and electronic goods will be described in Chapter 6. We will give here an initial overview of developments in the three countries at the forefront of progress on implementing EPR: the Netherlands, Germany, and Sweden. The Netherlands "In the Netherlands, EPR is the connecting link between product policy and waste policy. The general emphasis in product policy is on the responsibility and the role of producers in seeking to achieve an ongoing reduction in the environmental impact of their products. This responsibility extends not just to emissions during the production process but also to the choice and use of raw materials, the design of the product, the environmental effects during the product's lifetime and the disposal of the product at the waste stage." - Aart Dijkzeul, Head of the Division for priority waste streams, Ministry of Housing, Spatial Planning and the Environment, Netherlands [15]. The main motivation for EPR in the Netherlands was to internalise disposal costs in product prices thus providing an incentive to take preventive measures and to design for recycling. Currently the Netherlands has EPR for [15]: - car scrap (voluntary plus financial incentives); - packaging waste (voluntary and statutory agreements); - consumer batteries (voluntary backed up by statutory laws); - car tyres (statutory); - plastic construction materials (voluntary plus financial incentives); - agricultural plastics (statutory). Some more details are given in Section 4.2. Germany Germany has for some years had statutory take-back schemes for packaging (1991); the Environment Ministry has also proposed similar legislation for cars [16] (see Section 4.6). In 1994 Germany enacted a new Biocycle Law which will take effect in October 1996 [17]. The law rests on the principles of ecological design of products to make them suitable for recycling, higher priority to waste avoidance than to recycling, and EPR, among others. The German Enquete Commission's report (1994) on "Protection of Humanity and the Environment - Assessment Criteria and Prospects for Environmentally Sound Product Cycles in Industrial Society" [18] was the result of over two years' analysis of materials policy. Using the principles listed above, the Commission studied flows of cadmium, benzene, and sectors such as textiles, transportation, electronics, and chlorine production. By applying systems analysis the root causes of contamination could be identified. For example, cadmium prohibitions should be applied where closed-loop recycling within society is unrealistic; compulsory labelling, take-back and recycling for those consumer products already in existence (such as nickel- cadmium (Ni-Cd) batteries); restrictions of phosphate fertilisers to what is absolutely necessary; and health warnings on all tobacco products to warn consumers that smoking is the highest cadmium exposure risk to humans. Sweden "That which is extracted from nature shall be used, re-used, recycled or disposed of in a sustainable fashion with the least possible consumption of resources and without harming nature." - Principle of the Swedish Ecocycle Commission [19]. On May 26, 1993 the Swedish parliament adopted new guidelines for a national environmental policy in accordance with the Ecocycle Bill. For defining ways to implement the goals set by the bill, an advisory group was appointed. The group, called the Ecocycle Delegation or Commission consists of environmental experts from industry, trade, and NGOs, and is led by politicians from the ministry and parliament [20]. EPR was one of the most important new concepts introduced in the Bill. Different industrial sectors are approaching the problem in different ways [21]. The electronics industry is organizing itself in environmental councils, the construction industry is investing in research, the tire industry asked for and obtained legislation on producer responsibility while the Association of Swedish Automobile Manufacturers and Wholesalers advocates a voluntary commitment from all manufacturers and importers to participate in EPR on the basis of the Ecocycle Bill (see also Section 4.6) [22]. Producer Responsibility targets have been set [23]: - Tires: 60% reduction in disposal to landfills after 1996; 80% reduction in disposal to landfills after 1998; - Electronic goods: 85% take back by the year 2000; - Car take back: less than 5% weight to be landfilled or incinerated without energy recovery by 2015. At the same time, the Swedish Environmental Protection Agency is assessing the following material flows [24]: - metals (iron and steel, copper, aluminim, zinc, nickel, chromium); - plastics; - textiles; - paper and wood; - cement and concrete. 4. SUMMARY OF TOOLS TO ACHIEVE MORE EFFICIENT MATERIALS USE [25] 4.1 Corporate or industry-wide product stewardship programs Some companies and industries have seen the benefits of EPR to present and, increasingly, future competitiveness (based, for instance, on anticipation of future legislation), and to customer satisfaction. Motorola, manufacturer of cell phones in the UK, has set up a cellular phone take-back group with seven other producers: Nokia, Ericsson, Alcatel, Sony, Philips, Panasonic and Benefon. They will run a six-month trial in Copenhagen from June 1996. With this project, the group hopes to demonstrate to governments that voluntary schemes can provide an effective alternative to legislation [26]. These firms also hope that if a product levy to pay for take-back schemes is eventually introduced by law, sectors able to show that they are already collecting used products on a large scale will not have to pay the levy. In Sweden, Electrolux sees EPR as an opportunity for industry. This and other European examples from the electronics sector are described in Section 7.8. In Canada, a few companies are acting: - Xerox has had a corporate-wide international policy of product take-back for many years. The company will collect old equipment free of charge and re-use components still operable in new equipment [27]. - Black and Decker takes back batteries and cordless appliances [28]. The German Environment Ministry proposed mandatory take-back of used cars in 1992 (see Section 4.6). But German car manufacturers are also extending voluntarily their recycling operations to countries where the pressure to recycle is not as great, such as the UK [16]. In Japan Nissan is researching better design for disassembly, how to reduce the number of different plastics used, the best way to label those plastics to facilitate recycling and how to use more recycled materials in new cars [29]. In the US and Canada, Ford, Chrysler and GM are not as active as Nissan in take-back research design. However, they plan to label plastic components to identify the different polymers and have recently established a consortium with suppliers and recyclers to address the recycling issue [29]. But at present it is not yet economically feasible to separate and recycle car scrap materials, even though landfill fees can thereby be avoided. According to the US Office of Technology Assessment, a change in materials management in the US auto industry is unlikely to emerge without substantial new economic or regulatory incentives [29]. 4.2 Voluntary take-back or buy-back schemes Voluntary take-back schemes usually include financial incentives to make them succeed as well as backup legislation if targets are not achieved by voluntary action. Consumer awareness has often spurred voluntary agreements to phase out certain materials or redesign products for better recyclability. Example: Netherlands take-back of packaging and car scrap The Netherlands Packaging Covenant (Stichting Verpakking en Milieu, 1991) aims to recycle a minimum of 60% of used packaging which cannot be re-used [30]. This would include up to 75% recycling of plastics - a very high figure considering the low current average rate of about 8%. The covenant places a priority on refillable containers. However, because voluntary agreements do not ensure a level playing field, government regulations are often seen as essential. The Dutch covenants are indeed backed by the unavoidable invocation of mandatory regulations if industry does not act voluntarily. For instance, at the request of the Dutch car industry, the Dutch government introduced a surchage on new cars to finance mandatory end-of-life vehicle recycling [31]. Auto-Recycling Nederland (ARN) [15] is the result of a voluntary agreement between organisations of car manufacturers, importers and car dismantlers. ARN sets high standards for dismantling. The scrap dealers sell valuable materials to recyclers and ARN pays for the extra time involved in environmentally-sound dismantling as well as arranging contracts with secondary recyclers. There is no fee to the consumer for delivering a car to the ARN but a fee of NLG 250 ($CAN 205) is paid on every new car. Payment of the fee is linked to the Road Traffic Act. An important element of the system is that it is, once again, backed up by legislation. By December 1995, 200 dismantlers had joined the system. Together they dismantle about 75% of scrapped cars and it is expected that within a few years this figure will increase to more than 95% [15]. 4.3 Leasing schemes Leasing schemes are highly efficient and resource conserving, and illustrate how an economy based on utilization is ecologically preferable to one based on exchange value. In leasing, the owner maintains responsibility for repair and take-back. A product can be leased many times over, extending the product's life and cutting resource and energy use. Doubling the utilization period or product life of goods in markets near saturation cuts by half the need for raw materials and energy in production and reduces by half the amount of post-consumer waste without reduction in wealth or welfare. A semi-commercial washing machine in a laundromat, for example, requires 20 to 40 times less resource input per wash cycle (production, distribution, recycling) than a household washing machine, while giving comparable results [32]. 4.4 Deposit-refund schemes Deposit refund schemes encourage re-use. They were standard practice, most extensively for refillable glass bottles, before the age of disposable packaging and global trade. Denmark has legislated against the use of non-refillable beverage containers and implemented mandatory deposit schemes on refillable ones. It has made illegal the sale of beer, soft drinks and other beverages in cans [33]. A deposit of 1-3 krone (24-71 Canadian cents) per bottle has ensured 97% of beer and soft drink packaging is re-used or recycled [34]. (In Quebec, by comparison, an identical rate of return has been achieved by the 10 cents deposit on refillable beer bottles [35], while the 5 cents deposit on aluminium cans has only achieved a 72% return rate [36].) The Danish ban on cans as beverage containers was upheld in the European Court in 1988 after beverage importers filed a complaint that the free trade of goods was endangered [37]. Re-usable and refillable beverage containers are efficient within a regional economy. Once long distance transport becomes necessary, the energy efficiency is diminished. Sweden's deposit system for rechargeable Ni-Cd batteries is described in Sections 5.2.6 and 7.5. 4.5 Product taxes to fund waste management systems Product taxes can be charged to the producer to fund selective collection and waste management systems for specific materials such as tires, batteries and different types of packaging. The Swedish Ecocycle Commission has recently recommended that retailers and importers of electronic equipment add a take- back fee on each product [38]. This could be differentiated along the lines of the existing German packaging take-back system (see next Chapter) which uses a combination of a weight-based fee and an item fee based on the volume: in 1995, for instance, the fee for paper was 0.15 DM ($CAN 0.14) per kg whereas for plastics it was 2.95 DM ($CAN 2.71) per kg [39]. 4.6 Mandatory take-back requirements The first national take-back legislation was the 1991 German packaging law which stipulated targets for recycling. In 1996, the following rates of recovery must be achieved [40]: glass 72%; paper/cardboard 64%; plastic 64%; steel cans 72%; beverage cartons 64%; aluminum 72%. Since 1992 the German Environment Ministry has also been promoting the mandatory take-back by manufacturers of scrapped cars, free of charge. This draft law would also require manufacturers and car distributors to recycle a certain percentage by weight of the materials used, e.g., 100% for steel and 50% for plastics by the year 2000. German car manufacturers are working hard to meet these goals. BMW, Ford and Mercedes are modeling their take-back operation to work along the lines of the packaging take-back system, with a separate organisation to accept and strip down cars [16]. Focus: Mandatory car scrap take-back in Sweden Following the proposal of the Ecocycle Commission, the Swedish Motor Vehicle Recycling Act should enter into force on January 1, 1997. This will replace the Motor Vehicle Disposal Act which has been in force for over two decades. The new act's goal is that motor vehicle manufacturers and importers should assume joint responsibiity for recycling of end-of-life vehicles. As a result, on the basis of life cycle management, they will be ultimately responsible for ensuring higher recycling potential and reduction in the quantity of final waste [41]. The Government must set re-use and recycling targets as follows [41]. - In respect of vehicles recycled between January 1, 2002 and December 31, 2014, the amount of waste landfilled must not exceed, on average, 15 percent of the vehicle's specified reference weight. The total waste that is landfilled must not exceed on average 150 kg per vehicle. - In respect of vehicles recycled after Jan 1, 2015, the amount of waste landfilled and incinerated with energy recovery must not exceed, on average, 5 per cent of the vehicle's specified reference weight. The total waste that is landfilled must not exced 50 kg on average per vehicle. - An ecolabelling system must be introduced. - Producers must prepare a plan to minimize the waste generated by motor vehicles. The plan must be presented to the Environmental Protection Agency (EPA) in 1999. - Producers must mark all components and materials in their vehicles to facilitate sorting and recycling. - The Vehicle Disposal Fund will be renamed the Vehicle Recycling Fund. Producers already have retroactive physical and economic responsibility for tires under a separate ordinance [42]; their responsibility for cars will also be retroactive and include all vehicles irrespective of the year of manufacture, in order to create a strong incentive to develop vehicles that can be profitably recycled. A vehicle disposal charge is already levied on producers in connection with the registration of new vehicles to partly finance the payment of a vehicle disposal premium to the last owner, new vehicles financing the disposal of old through a rolling fund system. However, it is intended that take-back also apply to vehicles marketed before the introduction of the new system. For this reason the Vehicle Recycling Fund will continue to be financed by the state until the point where all end-of-life vehicles represent a source of profitable raw materials and there is no need of an incentive to hand in vehicles and recycle them. At that point the scheme will be totally producer financed. In the interim it is proposed that producers should initially receive a vehicle recycling premium of 800 krona per car ($CAN 165) for vehicles which they are obliged to dispose of, and that a vehicle recycling charge of 1300 krona ($CAN 269) be paid by the producers into the Fund for all cars registered in Sweden, to finance both vehicle recycling premiums and premiums payable to last owners. Producers will indirectly be refunded any amount that has not been paid out as an incentive to last owners. Providing there are sufficient funds, grants will still be made for local authority vehicle disposal campaigns but the Commission doubts whether it will be necessary to make grants for disposal campaigns once the producer responsibility system has been implemented [43]. 4.7 Incentives for de-materialisation or less resource use A systems approach to product use examines social dynamics in relation, for instance, to urban planning and transportation systems. For example, the aim of the EU Priority Waste Streams Programme working group on car scrap was to ensure the controlled disposal of car scrap in all member states [44]. The final report, however, also included measures to avoid car scrap through extending vehicle lifespan, more efficient use through car-sharing, strengthening of local and long-distance public transport, and the reduction of toxic material use in vehicles. However, these measures had no obligatory stipulation attached. This highlights one of the major challenges in the history of production. If we are to achieve a minimum reduction of resource use by a factor of ten [11], the value of utilisation and services will have to be dramatically enhanced relative to actual material consumption. 4.8 Disposal bans Disposal bans are a major factor in better resource recovery. In the Netherlands PVC has been phased out in packaging. In 1994 bans were pending on landfilling of over 30 waste streams including organic waste, recyclable cardboard and paper, tires, agricultural plastic, and building rubble will soon be banned from landfilling in the Netherlands [45,15]. 5. SUMMARY OF TOOLS TO ACHIEVE CLEANER MATERIAL USE 5.1 Materials or product taxes Product taxes are used not only to fund waste management (see Section 4.5) but also to discourage the use of certain materials or products such as leaded gasoline or virgin material, at the same time generating revenues. In 1993 Belgium introduced an eco tax system. Producers responded by changing the production processes of throw-away razors and cameras to manufacture only recyclable products before the tax was even implemented [46]. The Belgian tax on paper pulp is lowered by half if chlorine is not used in the bleaching process. As a result, industry now produces chlorine-free paper [46]. 5.2 Materials restrictions or prohibitions Many materials currently used in society pose unacceptable environmental and human health risks. For instance, many organochlorines and their waste by-product, dioxin, are now targetted for elimination in a range of international fora (see Chapter 2). On the national level, in many countries chlorinated solvents, chlorinated bleaching processes and chlorinated pesticides have increasingly been restricted, banned or voluntarily substituted. For instance, the chlorinated plastic, PVC, is restricted in over one hundred European municipalities as well as voluntarily substituted within commercial and institutional establishments. In Sweden, the Ecocycle Commission's recommendation to phase out all soft PVC and rigid PVC with harmful additives as speedily as possible was adopted by parliament in November 1995 (see Appendix). Sweden has also been a lead country in chemical phase-out legislation. Much of this action is predicated by the Substitution Principle found within the Chemical Products Act. This requires anyone producing, importing or using a chemical product to actively seek less hazardous substitutes [47]. The Swedish Chemicals Inspectorate drew up in 1991 the following list of thirteen chemicals to be targetted for restriction through various strategies and instruments [48]: 5.2.1-3 Methylene chloride, trichloroethylene and tetrachloroethylene Since January 1, 1993, methylene chloride, trichloroethylene and tetrachloroethylene ("perc") have been prohibited from sale in consumer packaging. Since January 1, 1996, solvents containing methylene chloride or trichloroethylene cannot be sold to or used by industrial users [49]. 5.2.4 Lead Leaded petrol is to be phased out via increased taxes. Lead shot will be phased out voluntarily. The Environmental Protection Agency (EPA) is preparing timetables to phase out the laying of new lead sheathed underground cables. Lead accumulators (including lead car batteries) will be phased out in the long term and the lead content of crystal glass will be reduced considerably. The EPA will promote the transition to lead free pigments in paint production. 5.2.5 Mercury Among other measures, the Swedish parliament has ordered the phase out of mercury oxide batteries by the year 2000 [50]; the sale of all thermometers containing mercury has been banned since January 1, 1993; the use of mercury in strip lighting will be phased out in the long term; and the use of mercury in dental fillings will be investigated for phase-out. 5.2.6 Cadmium Cadmium for surface treatment in plastics and dyes has been banned for many years in Sweden. A deposit system for rechargeable Ni-Cd batteries has been established and a tax on cadmium in fertilisers will be set. But since most cadmium enters the Swedish environment via transboundary air pollution (incineration, etc), the need for international bans is obvious. 5.2.7 Organotin compounds The use of organotins in plastics, paints and glues will be restricted or phased out. 5.2.8 Chloroparaffins The goal is to phase out the use of chloroparaffins entirely by 2000, in particular as a flame retardant/plasticizer in PVC plastics (see Appendix). 5.2.9 Phthalates Phthalates are a common air and water contaminant especially from flexible PVC production (see Appendix). In 1991 the Swedish Chemicals Inspectorate called on importers to report on the dangers of the product. Further measures were due to be decided after a compilation of reports. 5.2.10 Nonyl Phenol Ethoxylates These are used in detergents, emulsifying agents and dispersants. Consumer use will be phased out in a few years with a reduction for industrial use of 90% by 2000. Taxes will be increased for products that do not quickly phase out this chemical. Following the Swedish listing, the use of nonyl phenol ethoxylates in industrial cleaning will be banned by 2000 under a 1992 Paris Commission resolution of which fourteen European countries are signatories [51]. 5.2.11 Arsenic Arsenic has a key use in timber application. Atmospheric emissions are to be halved by 1999 at the latest with increased restrictions in product use. 5.2.12 Creosote The only use of creosote in Sweden is to treat timber (electricity poles). Research on substitutes will assess the feasibility of a complete phase-out. 5.2.13 Brominated flame retardants Brominated flame retardants are imported for use in plastics, insulation materials and circuit boards. Contamination is now widespread. However, they are difficult to eliminate in a given country because of international trade and the fact that chemicals are carried across water and air regardless of one nation's regulations. Sweden has taken the lead at the OECD to phase out releases of these substances internationally. 5.3 Environmental management and auditing systems Comprehensive company audits that assess raw material and energy use enable continuous improvement towards cleaner process and material choices. These can be extended upstream to suppliers of raw materials as well as downstream to product users. For instance, some German leather goods manufacturers now set standards for raw material quality of imports, such as fungicide-and chrome-free leather imports [52]. 5.4 Mandatory disclosure of environmental information Public disclosure of a company's use of toxic substances in manufacturing processes and mandatory pollution prevention plans under the Massachussetts Toxic use Reduction Act have led to cleaner processes. The state is set to achieve a fifty percent reduction in toxic use (1990 baseline) by the year 1997 [53]. Even crude emission data such as the Canadian National Pollutant Release Inventory facilitate public access to information and hence public accountability. 5.5 Eco-labelling Eco-labelling includes energy efficiency ratings, listing of product ingredients and/or statements concerning the potential environmental or health impacts of those ingredients, as on cigarette packs. Positive or negative, they attempt to sway consumer choice toward more environmentally sensitive purchasing. California's Proposition 65 has for a number of years mandated labelling of products that contain potential human reproductive toxins and carcinogens [54]. Plastic identification is clearly needed on a wider scale. 5.6 Government subsidies and tax credits Subsidies, by their very nature, encourage continued production and use. Environmentally-positive subsidies such as the tax credits for energy-efficient products in California [55] stimulate the market toward better ecological efficiency. However, most subsidies are used to maintain unsustainable processes and products [56]. Even the well established international Business Council for Sustainable Development has identified the subsidising of resource and energy intensive products and processes as one of the major bottlenecks to eco- efficiency [57]. 5.7 Government and institutional procurement of environmentally sensitive products and materials Government procurement of environmentally sensitive products stimulates the market and helps reduce costs to other consumers. In the US about 20 percent of the purchases of all goods and services is made by the various levels of government [58]. The USEPA has recently published guidelines for recycled paper products, re-used lubricating oils, retreaded tires, building insulation and cement [58]. Procurement policy was, notably, the driving force for PVC plastic phase-out by many European local authorities (see Appendix). 6. ELECTRICAL AND ELECTRONIC EQUIPMENT EPR - EUROPEAN OVERVIEW Every year eight to ten million tons of television and other electronic equipment "die" in the EU [59]. Currently most of this scrap is burnt or dumped, but draft legislation in several countries will require manufacturers to introduce large-scale recycling of electronic and electrical products before the year 2000 and as early as late 1996. Austria, Denmark, France, Germany, the Netherlands, Sweden, Switzerland, and the UK (and, outside Europe, Japan) are the countries most actively pursuing EPR for electronic products. These countries are calling for EPR from design to disposal. The EU is also grappling with an electronics recycling policy as part of its priority waste stream project which started in 1994 [60], with the Netherlands and Germany developing a common directive. In Europe, a new era of environmental accountability for electronics manufacturers is clearly at hand. While the goal of diverting electronic products from the waste stream is the same throughout Europe, the approach from country to country varies. While Switzerland and the UK (plus Japan) are taking the voluntary approach, Germany, the Netherlands and Sweden are leading the way with mandatory industry participation in product recovery and recycling [61]. All three countries have already developed draft EPR laws for electronic scrap. The Swedish approach will be dealt with as a detailed case study in Chapter 7. The draft Dutch and German electronics legislation places almost full responsibility for electronics recycling on manufacturers and importers of electronic products. The proposals will require manufacturers to establish collection systems for the recovery of products for recycling. Alternatively, industry can establish and finance private systems for collecting, sorting, dismantling and recycling used equipment [60]. The Netherlands: objectives for the electronic waste stream The Dutch proposal [62] is the most progressive in setting out a product take-back goal of 100% by the year 2000 with recycling targets for specific materials and re-use targets for specific products. Industry will have to meet the following qualitative and quantitative goals. - Prevention: achieve "as much quantitative prevention as possible" by reducing materials use and increasing the product's useful life. - Recovery: achieve 100 percent differentiated collection by the year 2000 for optimal product and materials re-use. - Product re-use: achieve "as much re-use as possible" of collected equipment. - Materials re-use: for waste remaining after product re-use, by the year 2000 achieve - 90 percent materials re-use for white goods (e.g., refrigerators, washing machines, dishwashers); - 70 percent materials re-use for brown goods (e.g., televisions, videos, computers, telephones) and other appliances (e.g., sewing machines, vacuum cleaners, coffee makers); - 95 percent materials re-use of metals in high grade applications; and - 30 percent material re-use of polymers (plastic) in high grade applications. Germany: Electronic Waste Ordinance In contrast, the German draft ordinance [62] does not specify recovery or recycling targets and timelines although, like Sweden (see Chapter 7), it calls for mandatory industry participation in product recovery and recycling. According to the ordinance wastes should be avoided and reduced by: - manufacturing equipment and components from materials that are environmentally acceptable and recyclable; - designing products that are easy to repair and dismantle; - setting up collection systems for used equipment which are "easibly accessible to end users and ensure a high level of returns"; - recovering and finding new uses for used equipment and components; and - assigning used equipment and components which cannot be recycled to appropriate waste disposal facilities. [figure 3] [63] For the purposes of the ordinance, electronic products include household and commercial products such as office equipment (e.g., personal computers, fax machines and telephones); televisions; large and small domestic appliances; entertainment electronics; laboratory and medical equipment; measurement, control and automation equipment; and data processing and telecommunications equipment. Office equipment will be the first to be recovered towards the end of 1996 [64]. (Note: Germany does not include incineration within EPR packaging waste management [40].) Other countries In Denmark a framework agreement on electronic scrap is expected to be agreed in summer 1996 and then implemented through voluntary schemes for each sector. The information technology and consumer electronics sectors have already submitted proposals for voluntary schemes [61]. The French government has proposed a target of recovering all electronic scrap by 2002 but is awaiting the results of several pilot projects before deciding how to proceed. France has not been supportive of EPR at the EU level [61]. The United States government is urging European electronics companies to lobby against take-back provisions for used equipment on the grounds that they constitute a barrier to trade [64]. However, it is still highly likely that the European Commission will propose framework legislation. The main reason for the US position is that US companies fear European take-back legislation will put exporters to the EU at a disadvantage, since manufacturers in the EU want imports to be treated in the same way as indigenous production. (Currently approximately 78% of western Europe's electronics market is accounted for by imports [64].) It is for such reasons that in Sweden (see Chapter 7) EPR costs are proposed for retailers and importers rather than for the original foreign producers [38]. 7. IMPLEMENTING EPR: SWEDEN'S APPROACH TO ELECTRICAL AND ELECTRONIC EQUIPMENT TAKE-BACK LEGISLATION [65] - A CASE STUDY In March 1995, the Swedish Environmental Protection Agency (EPA) proposed a draft Producer Responsibility Ordinance for all electronic and electrical products. The EPA advocates mandatory regulations no later than January 1, 1998 [66]. The producer is defined as the manufacturer, the importer or the retailer [66]. The proposal allows EPR be enforced retroactively, i.e. for products already on the market. More than 200000 tonnes of electronic and electrical products are scrapped annually in Sweden [67] - a volume that is expected to increase as a consequence of increased consumption. As elsewhere, most of this waste ends up at landfill sites and incineration plants. Subsequent Sections outline the issues and questions that, in the Swedish approach, have to be addressed and analysed on the way to establishing complete EPR for electronic goods. Illustrations are also drawn from other countries where pertinent. Despite the sectoral focus, these questions are generic and applicable to all product groups and regions. They are included here as a suggested model structure for the use of policymakers in planning product take-back and EPR in Quebec. 7.1 Formulation of environmental objectives There should be Clean Production criteria with specific timelines and goals, for example a reduction by a factor of between ten and fifty in material use by the year 2040. This means either a reduction of 1/10 to 1/50 in raw/virgin material use, or else ten to fifty times more use per product by this year. EPR is one factor in this medium-term plan. The Swedish proposal plans to recover 85% of all discarded electronic products by the year 2000 [66] (compared to 100% in the Netherlands - see Chapter 6). But in the longer term, the aim is to minimise all environmental impacts from these products during their entire life cycle. 7.2 Description of the product area It is essential to define the product area. The Swedish EPA defines electronic and electrical equipment (EEE) as products which are dependent on electric currents or electromagnetic fields in order to work properly, plus equipment for generation, transfer and measurement of such currents and fields. Also included are the components necessary for cooling, heating, protection etc. of the electrical components. In an assembled product only the components having an electrical function are included [68]. It is then necessary to ascertain the quantities involved, including: - the volume of goods sold in a certain year; - the volume of goods scrapped in a certain year; - the volume of goods imported and exported; - projections of future waste. Different goods have a different lifespan which must be planned for, e.g., cables last 40 years while computers typically last only eight years. The Swedish EPA estimates the quantity of this category of waste in the 1990s to be approximately 20-60 kg per person, of which consumer electronics and domestic appliances account for 20-25% [67]. If this figure is adjusted in line with the Swedish population, 25 kg/year (a conservative figure) will result in 215000 tonnes of waste from EEE each year. 7.3 Description of the environmental problems associated with the products For an assessment of material use the Swedish EPA has estimated the composition of most product groups. The main substances found in EEE are iron, copper, other metals, glass, ceramics, and 40 different types of plastics, with and without flame retardants [69,59]. The production of 10 tonnes of silicon chips requires 13000 tonnes of chemicals and 200000 tonnes of process water and generates 1700 tonnes of solid waste [70]. The production of printed circuit boards involves: - effluent contamined with copper, selenium, nickel and lead; - solvent emissions, both chlorinated and non- chlorinated; - spent etching solution waste, metal hydroxide sludge, and brominated flame retardants [71]. The use of plastics entails environmental and human health risks throughout their life cycle. PVC is particularly hazardous and Sweden is at the forefront of moves to phase it out (see Section 5.2 and Appendix). Natural materials and simpler plastic polymers that are easier to recycle are recommended instead. 7.4 Environmental problems at the end-of-life stage The problem with incineration [72] Waste incineration is a leading source of atmospheric emissions of dioxin and heavy metals. High emission standards cannot eliminate the metals, simply concentrating them into the fly and bottom ash which must then be landfilled. Similarly, emission control may do nothing to reduce dioxin formation. Most fundamentally, incineration can obviously not be part of a closed material plan. Incineration of PVC products is particularly dangerous because of dioxin formation in the flue gas and ash (see Appendix). Accident potential at waste sites Substantial dioxin releases from the accidental burning of stockpiled waste containing PVC have also been documented. For example, several fires involving automobile "fluff" stockpiled at automobile reclamation facilities have occurred [73]. Laboratory studies by USEPA indicate that burning one kilogram of fluff generates air emissions of approximately 0.0072 grams TEQ of PCDD/PCDFs (dioxin). The Agency estimates that approximately 2 billion pounds of autumobile fluff are generated annually in the USA [73]. The problem with landfilling Like incineration, landfilling is not a sustainable solution. Diminishing landfill space in European countries has been a key factor stimulating the introduction of EPR, especially take-back programs. Restrictions on disposal offer a direct incentive to develop more environmentally compatible products, which in the view of the Nordic Council, Germany and the Netherlands, brings a competitive edge to their industries. This is the reason why the Danish EPA is focussing on product design in their waste policies [74]. Very little research has been conducted on the behaviour of PVC in landfills, but it is known that plasticizers and/or heavy metal stabilizers present in PVC leach out into the percolate water (see Appendix). The problem with hazardous recycling Recycling of hazardous products poses problems within the recycling process as well as simply delaying the inevitable problems of final disposal. PVC, for instance, has been identified as being responsible for dioxin formation during metal recycling (see Appendix). It is the prime candidate for the origin of the dioxin emissions from Minraux Noranda's copper recycling facility at Rouyn-Noranda which fall clearly outside Canadian guidelines [75]. 7.5 Description of systems and facilities currently available for separate waste management of the products In Sweden only 1 per cent (3000 tonnes per year) of EEE waste is currently sent to a disassembly plant prior to further treatment [76]. Hazardous material (parts containing PCBs, mercury, cadmium) is sorted by hand disassembly from aluminum, steel, precious metals and plastic components [77]. The capacity of most facilities could be increased fairly easily by expanding the labour force. Not much machinery is required and there would be no great investment costs [77]. Secondary smelting works receive electronic scrap such as circuit boards and end-of-life telecommunication equipment. Although most scrap has previously gone to a disassembly plant some plastic remains and if this is PVC, it will cause dioxin generation in the smelting process - particularly in the presence of copper, which can catalyse dioxin formation [78]. Fragmentation plants crush electronic scrap which is then sorted. This generates emissions to air and water as well as solid waste residue which may contain heavy metals and PCBs [79]. Granulation of cables is a mechanical process that attempts to separate the plastic from the metals. 2500 tonnes of cables generates on average 200 tonnes of plastic residues plus 150 tonnes of lead, 750 tonnes of copper and 300 tonnes of aluminium. The metals are recycled but the plastic residue, previously used in Sweden for horse bedding, is now thought to be unsafe. This is because much of the plastic is PVC which contains flame retardants and hazardous metals posing a direct risk of soil contamination and health risk to humans and animals that come in contact with them [80]. Sweden already possesses regulations on the disposal of refrigerators and freezers containing CFCs. These have to be collected by municipalities and all CFCs extracted. Mercury switches must be removed prior to fragmentation and metals and plastic recycled to the greatest possible extent [81]. Battery disposal is also estimated to account for more than 90% of cadmium flow within Sweden. The industry collected 90% of spent Ni-Cd batteries in 1994-95 and these are sent for smelting. Mercury (button-shaped) batteries are currently being stored pending a further decision. As of 1994 a total of 1500 tonnes of batteries actually or potentially containing mercury were stored [82]. Appropriate treatment methods for cathode ray tubes [83] and plastic cabinets as well as markets for the plastic have yet to be found [84]. 7.6 Progress in other countries on environmentally sensitive scrapping and product development See Chapter 6. 7.7 Incentives for cleaner product development Sweden has identified government action for better electronic product development. More stringent controls within the existing permitting system are recommended for fragmentation plants and landfill plants that deal with electronic goods [85]. New regulations are proposed for stages in the life cycle of EEE that currently have no specific regulations, such as for granulation plants, and hazardous waste streams such as "fluff" [86]. As mentioned in Section 5.2, the Swedish Chemical Products Act contains a Substitution Principle which requires anyone handling or importing chemical products to avoid those that can be replaced by less hazardous ones. The EPA recommends more rigorous monitoring of compliance with the Chemical Products Act and better substitution within plants manufacturing EEE [85]. The Swedish Chemical Inspectorate's list of thirteen restricted substances is given is full in Section 5.2. EEE uses a wide range of materials including all of the listed substances except nonyl phenol ethoxylates, arsenic and creosote. PVC is not on the list, but, as mentioned above, Sweden is at the forefront of moves to phase it out (see Section 5.2 and Appendix). 7.8 Identify what government, industry and consumers can do regarding: - extension of lifespan; - recycling of components; - hazardous components and materials, i.e. which parts should be dealt with separately in order to prevent the emssion and dispersal of hazardous substances; how these components and materials should be disposed of; and what possibilities exist to replace hazardous substances with safer ones. This involves an assessment of all information from the previous points and consideration of implementation strategies for a particular region. Electronic products entering the waste stream today were not designed with recycling in mind. A lack of information on product composition, material variety and hazardous constituents present obstacles to recycling, particularly for plastics. Cost-effective recycling in the future will require product design changes that reduce disassembly time and increase the re-usability and recyclability of components, including: - product simplification; - standardisation of components and product configuration; - modular designs, including components for re-use; - standardisation of material types; - easily detachable parts; - reduction in the number of pieces requiring disassembly; - accessibility of components; and - reduction in the number of material types to reduce sorting. As noted previously, some governments have taken the lead with clear ordinances, having concluded that this and industry action are necessary before full consumer participation. Some companies have also been active. Electrolux in Sweden sees EPR as an opportunity for industry, and is developing environmental indicators such as recycling value. For instance, they calculate the recycling value of an end-of-life Electrolux washing machine at +$US 7.25 compared to -$US4.35 for a competing machine [87]. Electrolux is also focussing on added value based on material intensity per unit of service rather than just on the product itself. Increased leasing arrangements, for example, (Section 4.3) would help decrease the material intensity per unit of service provided. For now, however, the company is concentrating most of its efforts on recycling. By 1997 they will be able to calculate recycling values for most of their products in most countries [87]. At Sony Europe, new television designs incorporate more snap together parts and fewer screws, facilitating product disassembly. There are also fewer material types, reducing the amount of sorting required for recycling [88]. Siemens in Germany has designed a new eco-PC which facilitates disassembly in response to German electronics legislation. An added benefit of the new design is lower production costs. Fewer parts means less assembly time [88]. Delft University of Technology in the Netherlands is working with manufacturers of electronic goods under a Europe-wide project called CARE (Comprehensive Approach for the Recycling of Electronics) Vision 2000. The aim of this project is to recycle electronics scrap at the highest level of utilisation. It has led to a unique degree of co-operation between producers and recyclers. Industry participants include Siemens, Apple, Sony, Bang & Olufsen, Hewlett Packard and AT&T [89]. In the CARE system, every electronic product will contain an information module. This module stores all producers' information that can be useful to the recycler, such as the types of materials the product contains, the toxic substances that need to be removed etc. Another interesting possibility is to use the module to record information on the "life history" of a product to be able to determine its remaining "life value". For instance, the number of hours a cathode ray tube in a television has operated determines whether or not it can be re-used in a new product or as a repair part [89]. 7.9 Implementing control over current and future products The control of products throughout their life cycle is essential for EPR. This is why Electrolux [87] and others are considering leasing of products so as to retain ownership and control. Industry associations tend to favour voluntary schemes but then request legislation to ensure a level playing field, as seen with car scrap and tire legislation (see Chapter 3 and Section 4.2). Pending legislation is an effective boost for industry re-use and recycling programs. In Germany more than 40 manufacturers of electrical and electronic goods and waste management firms have begun building recycling networks [61]. Setting up voluntary agreements requires more administrative resources, both in labour and time, than legislation. This is especially so if one works on a case by case (or product by product) basis, as is the practice in the Netherlands. For example, the Dutch ban on landfilling for 30 waste streams only took two people and 18 months to introduce [15]. Voluntary agreements, after taking up so many resources, often then have to be followed by legislation. 7.10 Assessment of the costs and benefits involved in implementing the proposals In 1994, EU negotiators on product take-back were discussing three financial options: an end-users' fee; a new product fee, and a local authority tax. The negotiations resulted in stalemate since it proved difficult to harmonize the aspirations of more progressive countries, such as the Nordics, against more recalcitrant countries such as the UK [90]. The Swedish Ecocycle Commission recommended in April, 1996 that retailers should carry the responsibility of charging the take-back fee. According to the Commission the recycling properties and economics of a product should be visible at the point of sale (i.e., in the consumer price) [38]. Increased re-use and recycling generate increased employment as discovered in Germany with the packaging ordinance [91]. The service economy and increased utilization will require more labour but will be compensated by less resource and energy use. This, coupled with cleaner material use, will generate safer workplaces. A New York study shows that recycling one million tons of solid waste will generate 1600 jobs. Landfilling the same amount requires 600 workers and incineration only 80 workers [92]. Repairable products also promise employment benefits: employment in the American car repair business increased 50% between 1980 and 1990 whereas jobs in the manufacture of new vehicles increased only 3% [92]. 8. CONCLUSIONS AND RECOMMENDATIONS 8.1 The problem Waste generation in Quebec is out of control. Despite the introduction of a certain number of separate collection and recycling programs, we remain one of the most wasteful societies in the world. Not only do we generate far too much unsorted waste, but it is "managed" in a manner that can only be described as scandalous: landfill sites throughout Quebec systematically flout the law [93]; used tires flow in from Ontario and the US to fill hazardous dumps [94]; cement kilns, secondary metal smelters, municipal and other types of incinerators release dioxin and other pollutants into the atmosphere at levels that threaten public health [95]. In the face of this situation, while other countries are setting and achieving recycling rates of 65% or 85% and planning for the 21st century (see Chapter 3), the government of Quebec has presented us with a timid and vague proposal to reduce waste by just 50% relative to 1988 by the year 2000 [96]. It apparently lacks any vision of what will happen more than four years in the future. The current Hearings on waste management represent a unique opportunity to reject definitively this unimaginative approach. Those who are concerned with - and in some cases victims of -Quebec's waste scandal look to the Commission of Enquiry to set out instead an ambitious plan for massive waste reduction over the next two decades and more. This plan must be capable of inspiring all sectors of our society to assume their fair share of responsibility. Foremost must be the producers, importers and retailers who are the driving force of the consumer society. Here are powerful organisations who, while never ceasing to incite us to consume their products, have little thought for what will become of them once their short lives are over. It is individual citizens and hard-pressed municipalities who are left to deal with the consequences. Lacking resources, it is no surprise that they often do it poorly. This is why, in this report, we have concentrated on extending the responsibility of producers. 8.2 The solution: EPR Extended producer responsibility is not a vague, theoretical concept. EPR is current, tangible public policy in a range of countries who have had the courage to set about solving their own waste scandals. In Germany, for the past five years producers and distributors have been obliged by law to take back packaging. In just the first year of the scheme, while the economy grew, packaging consumption fell by 4% [97]. In the Netherlands, 75% of scrapped cars are dismantled by the car industry (Section 4.2) and blister packaging has "more or less disappeared" [15]. In Denmark, the sale of drinks in cans has been banned (Section 4.4). In Sweden, industrial associations are enthusiastic supporters of taking responsibility for the end-of-life management of their products [98]. Take-back is even present in Canada: in British Columbia, the paint industry collects and recycles waste paint [99]. The benefits to the environment are clear: the head of priority waste stream planning at the Netherlands environment ministry has "no doubt at all that in the Dutch situation EPR schemes are having a clearly positive environmental impact" [15]. And while timid governments and irresponsible industries will no doubt continue to make the excuse that EPR represents a barrier to trade, it should be noted that the four European countries cited above have been able to introduce their respective EPR schemes while remaining members of the world's biggest free-trade area, the European Union! Mandatory EPR in Quebec should, in fact, be regarded as a way to bring importers to account for the waste they indirectly create here - while encouraging our own exporting industry to adapt to the evolving EPR legislation in Europe and elsewhere. Progressive companies are already doing this. 8.3 Materials policy, not waste management policy A fundamental flaw of the government's consultation document [100] is that it deals with waste management in isolation. As demonstrated by the Dutch, with their "integrated chain management" [101], and the Swedes, who are trying to "close the ecocycles", waste can only really be dealt with as part of an overall materials policy, including, notably, a focus on products. Like the other Canadian provinces, Quebec has the jurisdiction to implement such a policy on a comprehensive scale. The federal government's jurisdication is limited to scrap materials that exhibit leachate toxicity under the federal and provincial Transportation of Dangerous Goods Regulations and the federal Export and Import of Hazardous Wastes Regulations. Most electrical or electronic scrap, for example, is considered to be non-hazardous material in Canada. Regulation of the collection and disposal of all non-hazardous waste materials is a provincial and municipal jurisdiction. Legislative and institutional structure But while competent to act, Quebec currently lacks the necessary legislative and institutional structure for both policy design and implementation. We recommend that: 1) Quebec should be given immediately its own Ecocycle Commission, an independent, publicly-financed policy-making body with the mandate to study material flows and make recommendations to reduce their environmental and health impacts. Foremost among its principles should be the 3 R's (reduction, re-use and recycling) plus composting. Its specific goals should include an agressive timetable for the reduction of waste going to "disposal" beyond the year 2000, including 80% reduction by 2010 relative to 1988; and the shifting of responsibility to producers through EPR. The Commission must be given the human and financial resources necessary to do this work properly. 2) The new Ecocycle Commission would naturally need to prioritize the most problematic material flows. As in European countries, tires, scrapped cars, electrical and electronic equipment, and packaging are in need of the most rapid attention. An appropriate methodology has already been laid out in Chapter 7. Product take-back schemes will naturally be a major focus of the Commission's work. 3) At the same time as the launching of the Commission, a parliamentary committee should be set up to study in detail the legislative framework of EPR in other countries, notably Sweden, and then to propose legislation along the lines of the Swedish Ecocycle Bill. Once passed, this would give legislative definition to the Ecocycle Commission. 4) The new industry-funded Solid Waste Management Corporation proposed by the government [102] should be retained but its role should be expanded to cover the practical implementation of the whole of materials policy as recommended by the Ecocycle Commission and endorsed by the government. Its name should reflect this expanded role, e.g., Ecological Materials Management Corporation. More efficient matierial use Whether Quebec is given its own Ecocycle Commission or not, the following measures are essential to achieve more efficient material use (Chapter 4): 5) As in recommendation 1, the government of Quebec must adopt an agressive timetable for the reduction of waste going to "disposal" extending beyond the year 2000, including 80% reduction by 2010 relative to 1988. 6) Waste reduction should be based on the 3 R's (reduction, re-use and recycling) plus composting, but must under no circumstances include "energy recovery", or any other form of incineration (see recommendations 14-18 below). 7) Waste reduction should be enforced by legislated bans on landfilling: - re-usable and recyclable materials within 2 years; - putrescible materials within 4 years. 8) Putrescible materials should be progressively diverted from regular garbage by the setting up, by the new Corporation, of a network of neighborhood composting centres. The Corporation should also expand funding of community 3R-composting initiatives such as the Ressourceries. 9) Not only should separate collection of recyclable materials be made mandatory (as proposed by the government [103]), but, within 2 years, the inclusion by householders of recyclables and hazardous household waste (HHW) in regular garbage should be made illegal. Verification should be carried out by random checks. 10) At the same time, retailer take-back should be expanded for drinks containers, in particular by increasing immediately the deposit on aluminium cans to at least 10 cents; and introduced for HHW, in particular for batteries, for which a deposit sufficient to achieve >95% take-back should be introduced as soon as possible. Refunding should be complete for refillable containers or re-usable materials, but only partial for recyclables - the difference going to finance recycling. 11) As in recommendation 2, mandatory, local producer and/or retailer take-back programs should be introduced for tires, scrapped cars, electrical and electronic equipment and packaging, following the European models (see Sections 4.2, 4.5, 4.6, etc.). 12) The government should immediately enforce its proposed ban on new or enlarged dry material dumps [104], and study with a view to adopting the Swedish approach for the management of construction waste [105]. 13) The labelling of the composition of all plastics sold in Quebec, including bags and film, should be made mandatory within 4 years, in order to allow a maximum of recycling (as well as identification of the more hazardous plastics such as PVC and polystyrene). Greenpeace is setting out its position on incineration in a separate brief [106]. For completeness, our recommendations concerning incineration are repeated here: 14) The government of Quebec should completely and irrevocably prohibit all new incinerators, including hospital waste and sewage sludge incinerators, industrial incinerators and hidden forms of incineration such as are carried out in cement kilns and plants that recycle metals contaminated by plastic and oils. 15) The government must close immediately the incinerator at Lvis in view of its scandalous dioxin emissions which are hundreds of times above Canadian guidelines. 16) The government must close within 4 years all other waste incinerators of all types (as specified in recommendation 14). 17) In order to reach this goal, the government must immediately launch public enquiries to investigate waste incineration activities in Quebec in each the four following four cases: a) cement kilns; b) metal smelters (including copper, iron and steel, aluminium and lead) which process metal-bearing wastes containing plastic and oil or grease; c) private incinerators run by industry, e.g., in the pulp and paper sector; d) waste dumps in the far North. 18) In the case of smelting and other secondary metal processing, the government should immediately see that the regulation currently in force which "prohibits the disposal of waste originating outside Quebec" [107] be applied. (Metal-bearing waste brought to these smelters orginates often outside Quebec [108]; its non-metallic content is burnt, i.e, disposed of.) Cleaner material use Increasing the efficiency of material use, however, is insufficient. We also urgently need to achieve cleaner material use (Chapter 5). This must not be brushed aside as irrelevant to waste management: hazardous products and materials become hazardous waste, and waste management is inseparable from materials management. In many cases, as with the incineration of PVC, apparently inoffensive products become hazardous precisely because of what happens to them when they become waste. We recommend that: 19) The government of Quebec should introduce mandatory toxics labelling legislation along the lines of California's Proposition 65, to ensure that any product containing substances that are known to be carcinogenic, neurotoxic, bioaccumulative or hormonally active according to established scientific criteria be labelled as such. 20) Complete listing of products' ingredients (as is already obligatory for food) and recycled content should be made mandatory in Quebec within 4 years. The labelling of paper and other products bleached with chlorine-containing compounds, and the labelling of paper with the percentage post-consumer recycled content should be made mandatory immediately. 21) The government of Quebec should contribute energetically to the work of the Federal/Provincial Task Force on Dioxins and Furans set up in 1995 to identify and characterize dioxin sources in Canada, and make all such information public. The numerous problems associated with the plastic PVC have arisen throughout this brief: this is a material that poses health and environmental risks at all stages of its life- cycle; it is, unfortunately, also present in our society in huge quantities (see Appendix). The government of Quebec must act immediately: 22) In collaboration with Health Canada, to coordinate the withdrawal of all lead-containing PVC from situations in which people come into physical contact with it; and to assess the corresponding risks from PVC containing other heavy metal additives, if necessary coordinating a similar withdrawal of this material too; 23) To ban the use of PVC in food packaging, where humans are especially vulnerable; and 24) To stop using PVC in new public construction projects. 25) The government of Quebec should set up a timetable for the phaseout of all other uses of PVC as follows: - all packaging material and other short-lived goods containing PVC including medical supplies within 2 years; - all other PVC goods such as toys, wallpaper, upholstery, flooring, pipes, window frames and siding within 4 years. Finally, let us observe that amongst the proposals the government of Quebec is making concerning waste management [100], there is scant mention of its own responsibilities to stimulate efficient and clean material use in society. In addition to ceasing to use PVC in construction projects (recommendation 24) and phasing it out in hospitals (25), it is essential that, at a minimum: 26) All departments and levels of the government of Quebec should immediately begin purchasing 100% post-consumer recycled paper bleached without chlorine-containing compounds for all routine uses (i.e., more than 95%); recycling all materials normally collected by separate collection; and setting aside all hazardous waste (batteries, paint etc.) for separate collection. * * * There is a strong tendency for countries to develop their national policies in isolation from the many positive examples available from elsewhere. The officials from the Ministry of the Environment and Wildlife responsible for elaborating Quebec's waste management policy appear to have taken little or no trouble to look at the progress that has been realised and planned in the countries we have focussed on in this brief - progress that in large part has been achieved by the concept of Extended Producer Responsibility. So what better way for the government of Quebec to lauch the new, ambitious, product-focussed materials policy that the Commission of Enquiry must recommend by the end of 1996, than to invite experts from around the world to an international conference on EPR in Quebec City in the Spring of 1997. Greenpeace will be there! APPENDIX. PVC: A MATERIAL WHOSE DAYS SEEM NUMBERED PVC, or vinyl, is the world's second most common plastic and most widespread organochlorine chemical. Its uses include construction (pipes, window frames), interior decoration (flooring, wallpaper, shower curtains), automobile interiors, electrical and electronic equipment, medical equipment, imitation leather, toys and packaging (bottles, clingfilm). Pure PVC contains over 50% chlorine by weight, and accounts for about one-third of the world's chlorine production, a proportion that has been rising as other chlorine chemicals, such as solvants, are phased out [109]. PVC production and disposal: a primary source of dioxin Concerns about PVC have focussed mainly on the pollution resulting from its production and disposal. It is produced by the chlorination of ethylene to make ethylene dichloride (EDC). EDC is then transformed into vinyl chloride monomer (VCM), which is polymerized into PVC. VCM is a potent liver carcinogen that has to be strictly regulated within the factory and during transport [110]. Numerous serious rail transport accidents involving VCM have occurred over the years, most recently near Magdeburg in Germany on June 1, 1996 [111]. Producers of EDC/VCM admit that the production process involves the formation of waste tars containing a range of hazardous organochlorine chemicals including dioxin, one of the most toxic substances known to science [112]. If this waste is incinerated, substantial quantities of dioxin are released into the atmosphere [113]. International and national policy agreements such as the United Nations Global Programme of Action for the Protection of the Marine Environment [6] and the Canadian Toxic Substances Management Policy [114] (both adopted in 1995), which aim to eliminate dioxin and similar compounds from the environment, will sooner or later have to confront the pollution from the PVC production process. PVC is also responsible for dioxin emissions at the end of its life cycle. In municipal and biomedical waste incinerators, the largest dioxin sources in industrial countries [115,116], PVC waste provides more than 50% of available chlorine [117] - the element essential to dioxin formation. Incineration researchers at the University of Florida are "convinced that, when all other factors are held constant, there is a direct correlation between input PVC and output PCDD/PCDF [dioxin]" [118]. For this reason the Danish government aims to avoid the presence of PVC in incinerators [119], and Toronto City Council has banned the incineration of PVC waste [120]. PVC is also burnt - and dioxin produced - during the smelting of scrap containing metals such as copper [78], steel [121,122] and aluminum, lead, and zinc [122]. The PVC is present, for instance, as insulation on copper cables or as the plastic component of scrapped cars. Environment Canada estimates that secondary copper smelting is responsible for up to 40% of Canada's atmospheric dioxin emissions [116]. PVC in construction and interior decoration materials has made accidental building fires another significant dioxin source [123]. The inquiry by D sseldorf Environment Department into the major fire that devastated the city's airport in April 1996 found that "PVC cable casing was involved... to a substantial extent" in dioxin formation [124]. Many European construction projects, such as the Channel Tunnel and several cities' underground train networks, now avoid PVC-coated cables [125]. The problems with recycling and landfilling Recycling of PVC is impractical because of the presence of numerous different mixes of additives to soften and/or stabilize the plastic, which explains why only tiny proportions of PVC undergo post-consumer recycling or genuine new production of the original products. PVC recycling is also hazardous: the Swedish parliamentary committee that assessed the Ecocycle Commission's 1995 recommendations on PVC found that "material recycling of PVC using current techniques cannot be recommended" [126]. Very little research has been conducted on the behaviour of PVC in landfills, but it is known that plasticizers and/or heavy metal stabilizers present in PVC leach out into the percolate water [127]. This could represent an important source of plasticizer emissions to soil and water. The heavy metal stabilizers (lead, cadmium and tin compounds) are an additional cause for concern over waste incineration, since the latter is known to be an important source of atmospheric emissions of lead and cadmium [128]. PVC use: a range of emerging hazards Increasingly, PVC is recognized to be hazardous not just in production and disposal, but also in use. In June 1996, US and Canadian Federal health authorities issued warnings that PVC window blinds containing lead stabilizers degrade on exposure to sunlight, releasing lead-containing dust that poses a serious hazard to children who might ingest it [129]. It seems likely that other PVC products exposed to sunlight, like house siding and window frames, have the same problem, and that the organotin stabilizers most commonly used in PVC produced in North America could be released in the same way as the lead. Health Canada is currently conducting a study on the leaching of organotin compounds from PVC pipes into drinking water [130]. Long-term exposure to these substances may affect the immune system and damage the liver and brain [131]. The plasticizers used to soften PVC also represent a health hazard. The most common plasticizers are the phthalates, which are thought to be the most abundant environmental contaminants [132]. 95% of the production of the most common phthalate, DEHP, is used in PVC [133]. Leaching from PVC is therefore almost certainly the primary source of this contamination, and PVC is the prime suspect in the recent scandal in the UK over baby milk powder found to contain worryingly high levels of DEHP [134]. DEHP is known to be hormonally active [132], and may turn out to be linked to a number of hormonally-related health trends in humans and wildlife, such as falling sperm counts. In the European Union DEHP has to be labelled as "environmentally hazardous" [135]. Worryingly, it continues to be used in medical equipment such as PVC blood bags. Another class of PVC plasticizers is the chloroparaffins [136], which appear on lists of persistent organic pollutants targetted for reduction or phase-out in ongoing international negotiations [137]. "The question is not whether to phase out PVC, but how..." This is how Swedish Environment Minister Anna Lindh welcomed the Swedish Parliament's decision in November 1995 that "today's plasticized PVC, as well as rigid PVC with environmentally harmful additives, should therefore be phased out. The phase- out should begin speedily" [126]. This is just the leading edge of a movement underway in countries across Europe, including [138]: - Austria: PVC-free resolutions have been passed by states and towns throughout the country, and the Supreme Court ruled in 1994 that PVC can be desribed as "an environmental poison" [139]. - Germany: over a hundred municipalities, including the capital Bonn, have PVC restrictions in place [140]. - Spain: in 1995 the Senate asked the government for a report researching the possibilities of a PVC phase-out. - Switzerland: in 1992, the government banned the used of PVC mineral water bottles [141]. In 1993 the Swedish-German flooring manufacturer, Tarkett, announced that it would abandon the use of PVC [142]. In March 1996 the principal Danish supermarket chain, FDB, made a similar announcement [143]. The Body Shop and furniture chain IKEA phased out PVC several years ago [144]. The organisers of the Sydney Olympics in Australia (2000) have committed to minimising the use of PVC [125]. In short, PVC's days seem clearly numbered. There is a rising tide of action to reduce dioxin emissions at national and international levels, and public health authorities are increasingly focussing on the health risks of the additives without which PVC is unusable. Given the easy availability of alternative plastics such as polyethylene, polypropylene, and PET, it seems only a matter of time before PVC bans and phase- outs at national level become widespread. REFERENCES Abbreviations PGD. Pour une gestion durable et responsable de nos mati res rsiduelles, Minist re de l'Environnement et de la Faune, 1995. ROE. Walter Stahel, A Regional Orientation of the Economy - A Key Factor in Sustainable Product Design in the Future Economy, Institut de la Dure, Gen ve, 1994. TIC. Third International Conference on Product-Oriented Environmental Policy with a special focus on Extended Producer Responsibility (EPR), Oslo, 15-16 February, 1996. MEE. Andy Stern, Managing Europe's environmental challenge, The Economist Intelligence Unit, London (UK), 1994. EPR. Extended Producer Responsibility: A new Principle for a New Generation of Pollution Prevention (Proceedings of the Symposium on Extended Producer Responsibility, November 14-15, 1994, Washington, DC), edited by Catherine A. Wilt and Gary A. Davis, University of Tennessee Center for Clean Products and Clean Technologies, June 1995. TES. Towards an Ecocycle Society, Swedish Environmental Protection Agency, ISBN 91-620-9525-0. CES. Closing the Ecocyle, Swedish Environmental Protection Agency, January 1995. PPR. Proposals on Producers' Responsibility for End of Life Vehicles in Sweden, Ecocycle Commission, Sweden, June 1995. EEE. Electronic and Electrical Equipment, The Basis for Producer Responsibility, Swedish Environmental Protection Agency, March 1995. RRC. Risk Reduction of Chemicals, Swedish National Chemicals Inspectorate and Swedish Environmental Protection Agency, 1991. IDF. L'incinration des dchets: une fausse piste qui menace la sant publique, brief presented by Greenpeace Qubec for the current Hearings. * * * 1. Politique quebecoise de gestion integre des dechets solides, Minist re de l'Environnement et de la Faune, 1989 (document 00.DA-4 of the current Hearings). 2. PGD, pages 35-36. 3. PGD, chapter 3. 4. H. Apsimon, I. Thornton et al., Anthropogenically Induced Global Change, Report of Working Group 3 - IUGS Workshop on Global Change Past and Present, UK, 1989. 5. The Oslo and Paris Convention for the North East Atlantic agreed in 1992 the goal of reducing, by the year 2000, discharges and emissions of substances which are toxic, persistent and liable to bioaccumulate, to levels that are not harmful to man or nature, with the aim of their elimination. In June 1995, the Fourth International Conference on the Protection of the North Sea recommended the end of discharges and emissions within one generation (25 years) with the aim of environmental concentrations close to zero for man-made synthetic substances. 6. Factsheet (Background Re: International Agreements on Hazardous Air Pollutants) distributed by Environment Canada at a workshop held at Hull, April 25-26, 1996. Also see document 00.DC-52 (1st attached document) of the current Hearings. 7. See document 00.DC-52 (2nd attached document) of the current Hearings. 8. EPA Draft Chapter on Dioxin Risk Characterization, May 1994. This document was made public as Health Assessment Document for 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds, External Review Draft, Volume II, EPA/600/BP-92/001c, USEPA, June 1994. 9. The Slow Birth of Green Chemistry, Science vol. 259, March 12, 1993. 10. Rens Meijkamp, No more products to be sold... in Green Product Design, Environmental Product Development Section, Faculty of Industrial Design Engineering, Delft University of Technology, December 1994. 11. J.L.A. Jansen and P.J. Vergragt, Sustainable Development: A Challenge to Technology, Ministry of Housing, Physical Planning and Environment, Netherlands, 1992. 12. Sustainable Germany, Wuppertal Institute for Climate, Environment and Energy, Carl Duisberg Gesellschaft e.V., 1995. See also F. Schmidt-Bleek, Wieviel Umwelt braucht der Mensch?, Birkhauser Verlag, Basel, Switzerland, 1994. 13. Towards Sustainable Europe, A Summary, Friends of the Earth International, January 1995. For a wider discussion of this see ROE. See also Business Council for Sustainable Development, Eco-Efficiency Workshop, World Trade Business Centre, 1994. 14. Government Strategies and Policies for Cleaner Production, UNEP, 1994. For more information contact UNEP Industry and Environment, 39-43 Quai Andre-Citro n, 75739 Paris cedex 15, France, tel. 33 (1) 44 37 14 50. 15. Aart Dijkzeul, Head of the Division for priority waste streams, Ministry of Housing, Spatial Planning and the Environment, Netherlands, presentation at TIC. 16. MEE, page 132. 17. The Closed Substance Cycle and Waste Mangement Act, Federal Ministry for the Environment, Germany, 1994. See Ursula Schliessner, From Cradle-to-Grave' to Cradle-to-Cradle', The New German Eco-Cycle' Waste Act: A Model for the Future, BNA International Environment Reporter vol. 17, no. 21, October 19, 1994, page 874; and EPR, page 19. 18. German Bundestag, July 12, 1994. 19. TES, page 2. 20. TES, pages 3 and 18. 21. CES, page 3. 22. PPR, page 34. 23. Strategy for Sustainable Development, Summary of Proposals for a Swedish Programme in Ett iljoanpassat samhalle (an environmentally adapted society), Action Program for the 90s, Swedish Environmental Protection Agency, 1993. See also CES, pages 21 and 31; and EEE, page 68. 24. CES, page 12. See also EEE, page 14. 25. EPR, pages 11-12. 26. Motorola leads take-back scheme for mobile phones, ENDS Report 253, Environmental Data Services, London (UK), February 1996. 27. Rank Xerox Environmental Performance Report, November 1995. 28. PGD, page 25. 29. Green Products by Design, US Congress Office of Technology, 1992, page 11. 30. MEE, pages 151-152. 31. Extended Producer Responsibility Programs, background paper to OECD International Workshop on Waste Minimisation, Washington, DC, March 29-31, 1995, page 8. 32. ROE. 33. EPR, page 30. 34. Interview conducted by the group of Leo Baas, Erasmus University Centre for Environmental Studies, Erasmus University, Rotterdam with Bent Serley, Danish Environmental Protection Agency, August 1994 (personal communication). 35. Recyc-Qubec, personal communication. 36. Consigne: volution du taux de rcupration, Recyc- Qubec, (document 00.DB-2.1 of the current Hearings). 37. EC Court of Justice sentence no. 302/86, September 28, 1988. 38. Swedish Ecocycle Commission, personal communication. 39. EPR, page 21. 40. EPR, page 20. 41. PPR, pages 8-9. 42. CES, pages 21-24 and 62. 43. PPR, page 71. 44. PPR, page 17. 45. Interview conducted by the group of Leo Baas, Erasmus University Centre for Environmental Studies, Erasmus University, Rotterdam with officials of the Dutch Ministry of Housing, Spatial Planning and the Environment, August 1994 (personal communication). 46. Accompanying document, Oslo Ministerial Roundtable Conference on Sustainable Production and Consumption, February 6-10, 1995, page 29. 47. RRC, page 27. 48. RRC, chapter 4 and subsequent chapters on individual substances. 49. Per Rosander, Greenpeace Sweden, personal communication, 1996. 50. EEE, page 11. 51. PARCOM Recommendation 92/8. 52. Marroquineria Ubriquena Hivall, leather producer, Cadiz, Spain, personal communication. 53. Toxics Use Reduction in Massachusetts, A Status Report, Toxics Use Reduction Institute, 1995. For more information contact Toxics Use Reduction Institute, University of Massachustts Lowell, One University Ave, Lowell, Massachusetts 01854-1866, tel. (508) 934-3275. 54. EPR, page 12. 55. EPR, page 11. 56. H. Yakowitz (OECD), Policy options to encourage cleaner production and products, in Nature and Resources Vol. 28, No. 4, UNESCO, 1992. 57. Claude Fussler (Dow Europe), Development of Eco-Efficiency in Industry, presented at UNEP Third High Level Advistory Seminar on Cleaner Production, Poland, October 1994. 58. Executive Order on Federal Acquisition, Recycling and Waste Prevention, USA Presidential Documents, Washington, DC, 1993. 59. J.C. van Weenen, Environmentally responsible development of electronic products, Milieukunde, Universiteit van amsterdam, February 1993. 60. EPR, page 62. 61. EU Priority Waste Streams Project Group at Odds Over Need for Directive on Electrical, Electronic Equipment, International Environment Reporter, May 17, 1995, pages 393-397. 62. EPR, page 63. 63. Reproduced from EPR, page 66. 64. US attacks European plans for electronic take-back laws, ENDS Report No. 253, Environmental Data Services Ltd., London, UK, February 1996, pages 44-45. 65. EEE. 66. EEE, page 69. 67. EEE, page 10. 68. EEE, page 5. 69. EEE, page 13. 70. EEE, page 15. 71. EEE, pages 14-15. 72. For a fuller account, see IDF. 73. J.V. Ryan, and C.C. Lutes, Characterization of Emissions from the Simulated Open Burning of Non-Metallic Automobile Shredder Residue, U.S. Environmental Protection Agency, EPA/600/SR-93/044, 1993. 74. The Danish Environmental Strategy, Danish Ministry of Environment, 1994. 75. See document 00.DA-121 of the current Hearings. 76. EEE, page 25. 77. EEE, page 33. 78. W. Christmann, Combustion of Polyvinylchloride - An Important Source for the Formation of PCDD/PCDF, Chemosphere 19, 1989, pages 387-392. 79. EEE, pages 34-35. 80. EEE, pages 35-36. 81. EEE, pages 36-37. 82. EEE, page 37. 83. EEE, page 51. 84. EEE, page 55. 85. EEE, page 63. 86. EEE, page 64. 87. Per Grunewald, Senior Vice President, Corporate Environmental Affairs, Electrolux, presentation at TIC. 88. EPR, page 70. 89. Gerda Zij, The dead television, CARE VISION 2000, a smart recycling system for electronics in Green Product Design, Environmental Product Development Section, Faculty of Industrial Design Engineering, Delft University of Technology, December 1994. 90. ENDS Report 247, Environmental Data Services, London (UK), August 1995, page 40. 91. Helmut Schnurer, German Federal Ministry for the Environment, presentation at TIC. 92. John Young and Aaron Sachs, Creating a Sustainable Materials Economy, Worldwatch Institute, Washington, DC, Paper 121, 1994. Also summarized in Worldwatch State of the World 1995. 93. PGD, page 17. 94. See Les site d'entreposage de pneus: des sites orphelins?, brief presented by the Comit de citoyens de Saint-Antoine- Abb et de Franklin for the current Hearings. 95. See IDF. 96. PGD, page 36. 97. EPR, page 17. 98. CES (throughout). 99. EPR, page 47. 100. PGD. 101. EPR, page 10. 102. PGD, page 38. 103. PGD, pages 42-43. 104. PGD, page 43. 105. CES, page 33. 106. IDF. 107. PGD, page 12. 108. See, for example, the letter dated July 18, 1996 and signed by Pierre Fabi, Ministry of the Environment and Wildlife (document 00.D-8.23.1 of the current Hearings). 109. Global ban on persistent toxic chemicals, Greenpeace International, September 1995. 110. H. Kollman et al., Stoffstr me end Emissionen durch Produktion, Verwendung and Entsorgung von PVC, JUEL-Spez-543, Juelich (Germany), 1990. 111. Benny Haerlin, Greenpeace Germany, personal communication. 112. British EDC producer ICI admitted that "it is difficult to see how any of these conditions could be modified so as to prevent PCDD/PCDF PVCdioxin] formation without seriously impairing the reaction for which the process is designed" in Report to the Chief Inspector HMIP Authorisation AK6039, ICI Chemicals and Polymers Ltd, Runcorn (UK), April 1994. 113. J. Hicks and S. McColl, Exposure Assessment of Airborne Dioxins and Furans Emitted from the EDC/VCM Facility at the Dow Chemical Canada Fort Saskatchewan Site, Institute for Risk Research, University of Waterloo, March 1995. Table 2 shows dioxin emissions of 5-10 ng TEQ/m3, more than ten times outside Canadian Council of Ministers of the Environment guidelines. 114. Toxic Substances Mangagement Policy, Ministry of Supply and Services Canada, 1995. Also see document 00.DC-52 (3rd attached document) of the current Hearings. 115. Estimating Exposure to Dioxin-Like Compounds, External Review Draft, Volume II, EPA/600/6-88/005Cb, USEPA, June 1994, Table 3-2. See also A.K. Djien Liem et J.A. van Zorge, Dioxins and Related Compounds: Status and Regulatory Aspects, Environ. Sci. & Pollut. Res. 2(1), 1995, pages 46-56. See also documents 00.DC-52 (6th et 7th attached documents) of the current Hearings. 116. Fact Sheets on Individual POPs (document distributed by Environment Canada at a workshop held at Hull, April 25-26, 1996). See also document 00.DC-52 (5th attached document) of the current Hearings. 117. Environmental Project No. 313 - Environmental Aspects of PVC, Danish Environmental Protection Agency, 1995, page 88. 118. J. Wagner et A.E.S. Green, Correlation of Chlorinated Organic Compound Emissions from Incineration with Chlorinated Organic Input, Chemosphere 26(11), 1993, pages 2039-2054. 119. Helle Petersen, Danish Environmental Protection Agency, presentation at PVC 96 Conference, Brighton (UK), April 23-25, 1996. 120. Open letter to Ms. Marion Axmith, Director, Vinyl Council of Canada, from City Clerk's Department, Toronto, dated May 3, 1996. 121. M. Tysklind et al. PCDD and PCDF Emissions from Scrap Metal Melting Processes at a Steel Mill, Chemosphere 19, 1989, pages 705-710. 122. J. Aittola et al., Measurements of Organochloro Compounds at a Metal Reclamation Plant, Chemosphere 27, 1993, pages 65-72. 123. See, for example, this study by the German Environmental Protection Agency (UBA): A. Fluthwedel et H. Pohle, Formation of polychlorinated dioxins and furans in thermal processes involving chlorinated organic products and natural materials [translation], Nachrichten aus Chemie, Technik und Laboratorium 41(10) (1993). 124. Translation of letter from Dr G rtz, Environment Department, Office of the Town Clerk, D sseldorf, May 8, 1996 (Madeleine Cobbing, Greenpeace International, personal communication). 125. PVC, in Olympic Report - 1700 days to the Sydney Olympics, Greenpeace Australia, January 1996. 126. Per Rosander, Greenpeace Sweden, personal communication, 1995. 127. Environmental Project No. 313 - Environmental Aspects of PVC, Danish Environmental Protection Agency, 1995, pages 95-96. 128. Discussion Paper on Possible Elements of a Heavy Metals Protocol under the UNECE LRTAP Convention, Prepared for Participants at a Workshop of the NAICC's HAPs Task Group, Ottawa, April 25-26, 1996. 129. See, for example, Ijeoma Ross, Blinds could pose lead hazard, Globe and Mail, June 26, 1996. 130. Health and Environmental Considerations Associated with PVC and Other Pipe Materials Commonly Used by the City of Toronto, City of Toronto Department of Public Health, March 18, 1996, page 11. 131. RRC, page 151. 132. S. Jobling et al., A variety of environmentally persistent chemicals, including some phthalate plasticizers, are weakly estrogenic, Environmental Health Perspectives 103(6), 1995, pages 582-587. 133. DEHP, Toxicological Profile, US Department of Health and Human Services, April 1993. 134. See, for example, Geoffrey Lean, Sex-change chemicals in baby milk, Independent on Sunday (UK), May 27, 1996; and Roger Crowe, Now PVC's image tarnished in wake of baby milk panic, The Guardian (UK), May 29, 1996. 135. Directive 92/69/EEC on the 17th adaptation to technical progress of Directive 67/548/EEC, July 31, 1992. 136. Canadian Environmental Protection Act, Priority Substances List Supporting Document, Chlorinated Paraffins, Government of Canada, 1993, Table 5.3. 137. Draft Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Control Persistent Organic Pollutants (document distributed by Environment Canada at a workshop at Hull, April 25-26, 1996), article 2. 138. Examples compiled by Thomas Belazzi, Greenpeace Austria, January 1996 (personal communication). 139. Vienna, September 19, 1994. 140. Old and new capitals in PVC-free future, press release, Greenpeace Germany, February 29, 1996. 141. Verordnung ber getrenkeverpackungen (decree on drinks containers), August 22, 1990. 142. We have decided on a major change - Tarkett is taking the first step away from PVC, press kit, June 21, 1993. 143. See article in Ingenioeren (Denmark), March 15, 1996. 144. Retailers Highlight Risk of PVC, Body Shop press release, June 16, 1996.