25 July 2006 Mr Tim Rogers


Re: NSW EXTENDED PRODUCER RESPONSIBILITY



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Re: NSW EXTENDED PRODUCER RESPONSIBILITY
PRIORITY STATEMENT 2005-2006 INTRODUCTION

AEEMA is pleased to provide this response to the EPR Priority Statement 2005-2006 released pursuant to section 18 of the Waste Avoidance and Resource Recovery Act 2001 (the Waste Act). As previously advised in our letter to the Minister, AEEMA has established an Environmental Policy Working Group made up of key member companies to meet the policy and strategic issues created by increasing government interest in product stewardship matters. This Group encourages policy debate and discussion across the membership and with the AEEMA Board about all relevant environmental matters in the public arena.


At the outset we wish to thank Departmental and Ministerial representatives for agreeing to meet with AEEMA recently to discuss various matters relating to waste management. This meeting was especially helpful to clarify directions and certain issues. During the meeting we agreed to provide additional data to Departmental representatives about efforts made currently to restrict the level and amount of hazardous substances in products by some suppliers. Two examples of this are attached.
We note that a Report on submissions will be published on 30 September 2006, and we request that this Report recognise that AEEMA no longer acts as the secretariat for the Consumer Electronic Suppliers' Association, (CESA) but we do have in our membership companies such as Motorola, Philips, Panasonic and NEC, which manufacture and supply consumer electronics products.
AEEMA's stated policy platform on the crucial issues surrounding waste management and resource efficiency can be summarised as follows:

  • promote the concept of developing a waste processing industry rather than placing encumbrances on the supply sector

  • promote, and convince governments to fund, programs of sustainable consumption alongside sustainable production

  • encourage the use of regulation only to the extent that is necessary and consistent with open trade in electronics/electrical sectors

  • ensure any regulatory framework guards against unfair competition in the marketplace

AEEMA notes and welcomes the stated commitment by the NSW Government to support voluntary rather than mandatory sector initiatives in the waste management debate. This approach recognises and encourages innovation and flexibility for industry, as the Priority Statement rightly notes. This is supported by international experience. In a paper published December 2005, the Network of Heads of European Environment Protection Agencies, stated clearly that "voluntary agreements between governments and industry can prove to be useful policy tools to promote innovative environmental practices particularly based on core, realistic regulatory frameworks accompanied by a series of specific voluntary measures and activities of common interest set up with a wide range of stakeholders". (The Contribution of Good Environmental Regulation to Competitiveness, p.3). Consistent with this recognition, mandatory take-back and recycling requirements for waste products can impose significant costs yet simultaneously fail to reduce environmental risks. Mandated recovery of higher quantities of domestic appliances over current levels would involve significantly higher marginal costs, but would likely result in little additional material recycling.
AEEMA

AEEMA membership is broad, covering all sectors from smart cards to IT security and data capture. But in particular, those members producing and supplying domestic appliances and lighting products are especially affected by all policy decisions made in any jurisdiction federal or state, relating to waste management and resource efficiencies. As such we state, again, that there remains an urgent need to ensure a more effective national waste management and resource efficiency strategy is adopted to avoid the unnecessary imposts on industry caused by fragmented policy development and jurisdictionally-based regulation.


This perspective has been recognised recently by the Productivity Commission in its Draft Report on Waste Management; "With so many parties involved in policy development, and different approaches being taken in different jurisdictions, waste management policy in Australia is for the most part, poorly coordinated." (page xxvi)




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