California Integrated Waste Management Board Contractor Report

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California Integrated Waste Management
BoardContractor Report
Framework for EvaluatingEnd-of-Life Product
Management Systems in California Presented by
Heidi Sanborn
July 10, 2007
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Presentation Overview

• Project Scope
• Framework to Analyze Systems
• Case Studies
• Recommended System Elements
• Implications for California
• Stakeholder Comments
• Summary

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I. Project Scope

• Report Provides CIWMB
• EOL System Evaluation Framework
• Eight Case Studies Using Framework
• Lessons Learned from Case-Studies
• Recommended System Elements
• Stakeholder Comments
• Implications for California

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II. Framework to Analyze Systems

• Funding Mechanism (fee or tax)
• Funding Approach (voluntary or mandatory)
• Fee/Tax Collection Point (POM, POS, POD)
• Fund Consolidation Point
• Fund Oversight
• Fund Management
• Program Oversight
• Program Operations
• Framework should enable comparison of EOL Systems
  and provide a basis for meaningful dialogue

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Applying the Framework III. Case-Studies

• 40 End-Of-Life Systems Selected 8
• Longevity (1989 2007)
• Data Availability
• Product Types - all hazardous, 4 U-waste/1 paint
• Special Features e.g. Auto Battery
• 5 State/Provincial 3 National
• 5 Mandatory 3 Voluntary
• Fee Collected from POM(6)/ POS(2)/POD (0)
• Applied Framework to the 8 EOL Systems
• Present Data as Reported

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Eight Selected EOL SystemsIII. Case Studies
(cont.)

1. Rechargeable Battery Recycling Corporation
2. Product Care
3. Maine Thermostat Law
4. Maine E-Waste Law
5. California Automobile Battery Take-Back
6. California E-Waste Law (SB 20)
7. California Oil Recycling Enhancement Act
8. Agricultural Container Recycling Council

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EOL Systems Trends/Lessons III. Case Studies -
Trends

• Funding Mechanism
• No taxes
• Visible vs. Invisible both fund Systems
• Funding Approach
• Voluntary has risks and mandatory levels playing
  field
• Fee Collection Point
• POM may be more efficient fewer stakeholders
• Fund Consolidation
• Producers can consolidate funds, government
  consolidation of funds grow government size and
  related costs

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EOL Systems Trends/Lessons III. Case Studies
Trends (cont.)

• Fund Oversight
• Can be performed by government or producers, but
  should be transparent and accountable
• Fund Management
• Government and producers can successfully manage
  funds but government funds run risk of being
  swept for other purposes
• Program Oversight
• Government and producers can successfully oversee
  EOL program
• Program Operations
• Wide variety of stakeholders which vary with each
  product

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IV. Recommended System Elements

• Funding Mechanism - Fee
• Funding Approach - Mandatory
• Fee Collection Point Manufacture
• Fund Consolidation PRO or Individual Producer
• Fund Oversight Government
• Fund Management - PRO or Individual Producer
• Program Oversight Government
• Program Operations Customized by product
• This Framework is recommended as the starting
  point for future discussions in designing EOL
  Systems.

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Considerations in Utilizing FrameworkLegislativel
y-Mandated Systems

• Role of Government
• Mandates participation no free-riders
• Performance based regulatory framework
• Requires transparency and accountability
• Planning for Program Evolution
• Systems will evolve
• Design flexibility into the System
• Market Forces
• Products with value will require less government
  involvement (e.g. lead-acid batteries)
• Mutually Beneficial Partnerships
• Stakeholder collaborations can lead to creative
  solutions

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Phase IV. Implications for California

• Request producers begin designing Program
  Operations
• Offer support in convening stakeholders
• Determine timeframe and milestones to achieve
  100 collection goals
• Establish baselines, formula to calculate
  collection rates, how to measure effectiveness

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Phase IIV. Implications for California (cont.)

• Draft regulatory framework
• Adopt policies on desired role of government,
  producers, retailers, others
• Communicate roles of DTSC and CIWMB for EOL
  Systems
• Include EPR in state procurement
• Consider banning sale of products on
  demonstration of successful collection System
• Consider banning sale of products when banned
  from disposal if non-hazardous substitutes exist
• Consider adoption of enforcement policies with
  adoption of EOL Systems
• Hosting workshops to learn from experiences of
  other countries and EOL Systems
• Continue to build CIWMB library and ensure staff
  access to conferences on EOL Systems

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VI. Stakeholder Comments

• Comments California Retailers Assoc. Regional
  Council of Rural Counties Clean Harbors Waste
  Management National Paint and Coatings
  Association National Electronic Manufacturers
  Association (battery, lamp, TRC) Kinsbursky
  Brothers Association of Lighting and Mercury
  Recyclers California Conference of Environmental
  Health Directors Rechargeable Battery Recycling
  Corporation.
• No Comments IKEA City of Los Angeles
  Californians Against Waste Product Stewardship
  Institute, California Refuse Removal Council.
• Submitted after the deadline and were not
  incorporated into the report.

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Is the Framework a Useful Tool? VI.
Stakeholder Comments

• Agree
• NEMA Battery Group
• Regional Council of Rural Counties
• Clean Harbors
• Disagree
• NEMA Thermostat Recycling Corporation
• No Response to the Question
• National Paint and Coatings Association
• California Retailers Association
• Kinsbursky Brothers Inc.
• Association of Lighting and Mercury Recyclers
• Waste Management Inc.
• NEMA Lamp Group
• California Conference of Environmental Health
  Directors
• Rechargeable Battery Recycling Corporation

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Framework Recommendations VI. Stakeholder
Comments

• Agreement
• Fees
• Fund Consolidation, Management and Oversight
• Program Operations and Oversight
• Disagreement
• Visible or Invisible Fee
• Mandatory vs. Voluntary
• Ultimately, the consumer will always pay.

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VII. Summary

• Report Provides
• Analysis tool - framework
• New information - case studies
• Language for dialogue
• Recommendations on next steps
• Basis to begin discussions on EOL Systems