For the interests of the recycling industry to be protected, it needs to be “a core actor in the EPR schemes’ governance and technical expertise”, Mr Rosales maintained. FEDEREC’s position statement also calls for the recycling industry to retain “the capability to sell our products”, he stated. “Ownership is a big issue for us. If we are not the owner of the material, we are not able to sell.”
FEDEREC also wants to ensure that the period between reviews of EPR schemes is sufficiently long to encourage investment. In addition, it is recommending the establishment of an independent entity to monitor company data in order to avoid confidentiality issues.
An insight into developments in Latin America was provided by environmental lawyer Russell Fraker of US-based Beveridge & Diamond, who began his guest presentation by stating: “There has been a flood of waste laws in the last 10 years or so, with EPR provisions in most of the major markets of the region.” Most of them “have not geared up on implementation”, he added, “but it’s coming – the laws are on the books and, little by little, they’re getting started.” And he also pointed out: “The majority of the market space in Latin America for electronics is under some kind of e-waste take-back regime.”
Specifically with regard to the take-back law enacted in Brazil four years ago, reverse logistics provisions have been applied to batteries, tyres, lamps, electronics and packaging. In theory, responsibility for devising the different sectoral agreement proposals lies with industry; in practice, said Mr Fraker, the government has been taking the lead. Pointing to “significant issues and certain problems in implementation”, Mr Fraker noted by way of example that the agreement on electronics “looks like it’s in some jeopardy of not moving forward” and “is certainly not on schedule”.
On a positive note, Mr Fraker highlighted Brazil’s success in the past with recycling programmes; for example, the country is said to enjoy the world’s highest recovery rates for aluminium cans and pesticide packaging. Therefore, there is every possibility the electronics scheme will be “pretty successful once they get organised”, he concluded.
Also at the meeting in Miami, which was chaired by Olivier François of NV Galloometal, the BIR’s Environmental & Technical Director Ross Bartley outlined latest developments at the UN-EP Basel Convention regarding the framework for the environmentally sound management (ESM) of hazardous and other waste. He expressed concern that latest work involving the Basel Convention’s Expert Working Group could result in “the bar for facilities in the industrialising countries ending up higher than what is required within the OECD” – an outcome that would have the potential to “cause some stress later on”.
