25 July 2006 Mr Tim Rogers

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AEEMA supports the cost-effective recovery and recycling of waste products and full life-cycle consideration of social, economic and environmental costs and benefits, to ensure there is informed policy consideration of whether regulatory approaches such as extended producer responsibility (EPR) should be pursued for any given product. But it should be noted that uniform waste policies may not suit all types of products or sectors. As an example, waste management approaches suitable for smaller domestic appliances do not readily translate to large domestic appliances (rarely suitable for landfill treatment) and lighting products. The environmental concern to recycle lighting products, for example, must always be balanced with the cost to transport end of life product over substantial distances. With those materials considered to be hazardous, the impact of transport, possible accidents, and attendant safety considerations mean that they cannot be managed in the same way as other items. The market for ewaste is not homogeneous and it is necessary to differentiate between, say, computers, televisions, and other types of ewaste. Not only are those products not as easily shipped as smaller consumer products but there is not a robust market for reuse through refurbishment. So a targeted policy framework is required that is suited to the particular characteristics of the item in question.

AEEMA wishes again to highlight the importance of a balanced approach to regulatory imposition and to caution against heavy-handed regulation. AEEMA supports a policy framework that promotes the concept of 'recovery where justified' and 'regulation where appropriate'.

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