25 July 2006 Mr Tim Rogers


AEEMA does not represent industries that use re-chargeable batteries in their products, other than mobile phones and emergency lighting, addressed elsewhere



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AEEMA does not represent industries that use re-chargeable batteries in their products, other than mobile phones and emergency lighting, addressed elsewhere.
2. Specific proposals or current actions on improving the recovery and recycling of NiCad batteries from emergency lighting and exit signs with a further report on implementation by 31 October 2006.
There is no NiCad battery recycling facility in Australia. Discussions continue with Cleanaway regarding collecting and shipping batteries to Europe.
3. Measures to improve labelling to educate consumers on options to recycle or safely dispose of used NiCad batteries with a progress report by 31 October 2006.
As there is currently no effective recycling facility in Australia to which consumers can be directed, any educative labelling on safe disposal techniques will not be able to provide consumers with any useful advice.
4. Initiatives to improve or establish systems for collection and recycling and to reduce hazardous substances in whitegoods, consumer electronic and lighting products.
There is already an effective system in place for the collection and recycling of major white good appliances; the intrinsic value of the metal in these products makes their recycling efficient. We believe these systems are adequate and support the conclusion of the Productivity Commission that any proposed EPR regime should be rigorously tested for net benefit. (Draft report page XXXIII).
Regarding hazardous substances, the current inquiry into the possible introduction of ROHs into Australia has put this item into the National arena. Our members are already voluntarily introducing ROHs compliant components into their products, resulting in a decline in the level of these substances. AEEMA has made a submission to this inquiry and supports the introduction of ROHs as long as it is regulated nationally and with proper consultation of all parties. Another important issue is that some hazardous substances such as flame retardants are used in these products for safety reasons, and AEEMA will continue to support stringent safety standards for the benefits of consumers.
Lighting products contain some materials that are required for safety and on the basis of current evidence AEEMA considers safety benefits outweigh perceived concerns about hazardous substances. Lighting Council Australia is currently working with regulators and standards organisations to reduce the level of mercury in lamps sold in Australia. The recycling of lamps in Australia is problematical because of their fragility in transport and collection. Costs associated with recycling a fluorescent lamp exceed the cost of the lamp itself, and industry will not undertake any recycling activity that is so patently uncommercial. As the Productivity Commission has warned, "policy makers... need to be guided by open and rigorous analysis of costs, benefits and risks..." (Draft Report, page xxxv)
5. Specific proposals or current actions to reduce the amount of shredder floc going to landfill for end of life whitegoods with a further report by 31 October 2006. Proposals or actions could include dismantling non-metallic components prior to shredding, developing ways to separate material from shredder floc or developing end markets for shredder floc.
Efficient and safe energy recover of shredder floc is only possible if it is shipped to Japan or Europe for treatment. Costs of this option outweigh the benefits and thus the option does not represent sound commercial sense. Dismantling and/or separating materials from floc similarly represent costs in excess of benefits. AEEMA does not consider it an appropriate or achievable obligation on suppliers or an industry sector to "develop end markets".

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6. Specific proposals or current actions on focussing the attention of the commercial sector on improving the recovery and recycling of fluorescent tubes and other vapour lamps with a further report on implementation by 31 October 2006.


See response to 4. above


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