This document is a written response to an invitation from the Environmental Audit Committee as a contributor to the inquiry into Electronic Waste and the Circular Economy dated 28th April 2020


Q.1 Has the UK got the balance right between prioritising recycling e-waste and making efforts to encourage greater reuse and repair?


Given the rate at which products are created, designed, developed, transported, purchased, consumed and discarded there is no simple answer to this question. The EU Right to Repair measures represent a positive move forward in encouraging repairability e.g. through the availability of spare parts and the UK Government has the opportunity to apply these principles to a broader category of electrical and electronic products, e.g. ICT equipment.  There are two specific areas I would encourage the EAC to consider:


1. Work with private, public and third e-waste sector organisations and encourage them to invest and review training, job pathways and skills acquired in reuse and repair.


Research indicates the need to further understand the supply and demand dynamics within e-waste.  In practice current policies appear to encourage resource recovery as a more profitable option. This policy can be explained in part because of the labour/operational costs attached to reuse/repair work and the demand for second-hand goods (either in the UK or outside). However, if past performance is any indication, funding allocated to third sector organisations does provide, the platform to offer some training in repair for certain products e.g. large domestic appliances and discarded technologies. But the pathways for employment appear to be limited seemingly because the training is not formally recognised by potential employers or the dearth of jobs available.


If the UK wants to encourage greater reuse and repair then fiscal and employment policies needs to change in order to support viable career pathways, for example, recognised training pathways through third sector organisations.


There is a delicate balance between supporting social initiatives that encourage the general public to repair their products, and recognising the skills required to carry out repairs. My view is that there is the potential for further job opportunities.  One frustration arises from the legacy connected to the social status associated with the manufacture of new equipment whilst failing to acknowledge the skills people need in order to repair, reinvent and renovate malfunctioning equipment.


Some supporting documentation:


2. Continue research into the flows and fates of discarded electrical and electronic equipment in order to better understand the dynamics of the market and product destinations.


Our research indicates that current forecast models work on the assumption that one electrical or electronic product placed on the market will equate to one product off the market which ends up in the waste streams. Given that some of the government WEEE collection targets have not been met, is a strong indicator that we need to better understand the flows and fates of EEE. Forecasting methods could include further insight into historic and production and trade statistics, in combination with product lifespans. Outputs from electrical and electronic products placed on the market and waste generated tailored for the 14 UK categories; socio-economic factors that reflect consumption trends, and market and technology trends that impact on purchase, weight, end of life patterns, reuse and recycling.


By taking an holistic view it could help to more accurately set targets for WEEE legislation, review the costings that producers pay for the end of life process, gather further intelligence on other market actors (e.g. business to business WEEE, unregistered online sellers, hoarding of EEE at home, exported second-hand EEE etc.) and further reuse and repair opportunities. The research indicates that commercial organisations have a shorter operational life for some products, which creates an opportunity for the capture for reuse and resale. For example, if we make e-waste collection more readily available (e.g. encourage further take back schemes), this might encourage a market for reuse/repair.


Some supporting documentation:



Q.2 Exporting e-waste has been linked to a number of problems in developing countries, but are there also some benefits?


The 2019 e-waste transparency project undertaken by the environmental justice charity, Basel Action Network, undertook a 2-year study by putting GPS tracking devices in electrical and electronic products and distributed them to recycling facilities in order to track the goods through to their final destinations. Their findings flagged the UK as one of the worst offenders. The research indicated the goods were traveling to Africa – Nigeria, Ghana and Tanzania and also Romania, Ukraine, Pakistan, Thailand and Hong Kong.


Additionally, in 2017 the UN initiated a system-wide response to tackling e-waste and called for collective responsibility encouraging further collaboration with governments and business. The report outlined the opportunities and how these actions contributed to the Sustainable Development Goal’s Agenda - in particular SDG 3 Ensure healthy lives and promote wellbeing; SDG 8 Decent work and economic growth; SDG 11 Make cities inclusive, safe, resilient and sustainable; SDG 12 Ensure sustainable consumption and production patterns.


With the above in mind, there is the opportunity, in partnership, to invest in setting up sustainable discarded electrical and electronic product management systems that not only support future livelihoods and wellbeing and encourage a more inclusive circular economy, but it could also be a potential source of critical raw materials and/or material by-products.


Agbogbloshie, in Accra in Ghana is unfairly given negative press as being an e-waste dumping ground. But speaking from first-hand knowledge from visiting this site and speaking with individuals working within the local community, I found it to be a hive of activity that requires recognition, investment and support.  For example, the German Government launched a 25-million-euro e-waste project in partnership with Ghanaian Government, Mountain Research Institute and local community to begin to develop a more sustainable infrastructure building a recycling centre, medical centre and football pitch. There are numerous benefits for all collaborators, including:



A similar system could be set up in the UK. We would need to ensure that we understood the environmental impacts attributed to the logistics attached with this development to ensure we were not further contributing to pollution, such as increased transport, ensure investment took the needs of the local communities in country to ensure they were not disadvantaged.


Some supporting documentation:



Q.3. How can the Government better support the recovery and re-use of the critical raw materials found in electronics?


As indicated in question 1, understanding the flows and fates of products is crucial to recovery, extraction and re-use supporting an assessment of available stocks.  And too there are also system wide changes that are needed regarding our products, as outlined above in question 2.


Some supporting documentation:


Q.4. What policy actions could the Government take now that we are leaving the EU to incentivise repair, reuse or resale of electrical and electronic goods?


As outlined in question 1, the Government should consider the fiscal impact relating to labour and the opportunity to invest and recognise the work individuals do to create the electrical and electronic resource flows within the economy.


In conjunction with the above, the Government should support our repair community. We should revisit opportunities to further support the SME’s in this area, by some of the elements Professor Cooper indicated when giving evidence on the 28th April e.g. availability of the manuals etc. Whilst at the same time continue to support charities and social enterprises that are operating in this space. Some offer training in repair as part of back to work schemes, others support the general public’s interest in repair such as RESTART projects or the recycling shopping arcade ReTuna Recyciln Galleria’ (in Sweden, turnover equated to £860,000 in 2017). Furthermore, subsidies could be given to support producers and encourage them to expand in remanufacture with more repair/refurbishment operations (e.g. modulated Fees).


Finally, IT Asset Management Companies appear to have useful business models that look for value for the whole waste hierarchy, that could be considered for other products. The Government, too, could create further collaboration within the sector by subsidising partnerships between producers, with repairers such as SME’s or third sector organisations. An example of this is the partnership between Dixon’s and the British Heart Foundation.


Supplementary material:



Q.4a What is the role for stronger regulation? Could we encourage a % of use of recycled materials?


A study by the Nordic Council of Ministers looked at plastics in electrical and electronic products. The study showed that most electrical and electronic products are, typically, made up of 20% plastics. I raise the question, can the Government incentivise producers to reuse a % in all new products, as is indicated in the ‘Our Waste, Our Resources: A strategy for England’ for single use plastics?


We need to be mindful of creating path dependencies for electrical and electronic products at the development stage. Further research and development is necessary to explore:


The Government could expand the Right to Repair Principles to encapsulate more products. For example, ICT’s, but this is not included in the products. Furthermore, when we are reviewing the financial value, we should include the social and environmental cost saving made from not using virgin materials and the social benefits in regard to new growth and job opportunities in repair.


Supplementary material:


Q.4b. Are you surprised about e-waste stream not being in the Environmental Bill?


Given the complexity attached to electrical and electronic products and current regulations surrounding them this will, take time – especially with some of the suggested measurement requirements. Anecdotally, I have heard employees working in the ICT space, mentioning the resistance of sharing CO2 measures because of the challenge of calculating this accurately, plus the sensitivity surrounding their supply/value chains and potential backlash from consumers.


I believe it is a opportunity to encourage the sector to start including additional metrics that are indicated in the Environmental Bill. I suggest a change in wording from resource efficiency to effectiveness (or efficacy?). For example, we could be efficient at urban mining but, as Tanya Sheridan (Policy and Evidence Manager at the Royal Society of Chemistry) indicated, this might not be effective as it could create further chemical reactions and pollution.


Q4c. Post BREXIT targets, is this a source of concern? Should we reduce the targets or increase our ambition?


The UK has missed its targets for the past couple of years and the first quarter of 2020 indicates the same will take place this year. In particular small household appliances such as, electrical and electronic tools, toys, leisure and sports, medical devices, photovoltaic panels appear to be amongst the discrepancies between forecast and what is collected. [Having different targets for different categories would help to retain visibility of areas which require further focus and move us away from just thinking that weight is important, especially with resource scarcity, instead focus on all products and seek opportunities for improvement.


The response to question 1, point 2 is relevant here, encouraging a more dynamic understanding of the flows and fates of our goods.


Q.5. What would be the most effective way for the Government to improve public awareness of the right way to dispose of and recycle electric products?


Some research indicates that there is a difference in people’s attitudes towards doing things and what actually happens in practice, as Tanya Sheridan (Policy and Evidence Manager at the Royal Society of Chemistry) indicated, there is a host of reasons why people hoard certain items and not others.


Further recognition of the differences in communities relating to affluence, accessibility, age and disposal practices, needs to be given. To raise awareness of the right way to dispose Government could consider the following:


1. Financial incentive - Even with the changes in regulation that requires retailers to offer take-back schemes, further incentives for returns by deposit could be introduced, such as working with producers/retailers of electronics to support business models and financial systems that encourage deposit schemes. For example, when purchasing a kettle, toaster or power tool, it could be advertised that upon return x pounds will be taken off the next purchase or, alternatively refund the equivalent amount when it is returned. This also provides the opportunity to raise public awareness, showcase where the discarded product is going e.g. to a repair centre/for sale on an auction site (e.g. gumtree, e-bay etc.) and/or used back into the production process, reinforcing the value of the product, brands sold in stores – plus there is the opportunity to include environmental and social benefits – create a narrative around the life of the product.


2. Lead by example, how many reused/refurbished electrical and electronic products does the UK Government procure and use? Further transparency and visible about the improvements being made.


Some supporting documentation:



Q.5a. Curb side collection, is this a possibility?


Not all citizens have transport or the ability to carry cumbersome items back to stores or to civic amenity sites for disposal. Funding could be provided to pilot a collection scheme, either operated by an ‘App’, not dissimilar to the platforms that sell materials, or by telephone.  For example, the Uber for Trash App in New York. The Recycle Track System, tracks waste items from collection to destination e.g. recycler/reuser/remanufacturer, but has adopted the ride share technology to connected independent collectors to pick and collect. A similar approach could be used for independent house clearance, transports or collectors of waste.  Or another app is Baidu in China connecting users to certified disposal and recycling facilities.


Also, these scheme details could be included on the household bin collection date leaflets – we cannot assume everyone is digitally savvy and/or wants to use data gathering systems. Charities that accept certain high-value products are good examples of how such a system could work, but that includes and excludes certain products. Retrieving, goods from households would also support the producers in getting the feedstocks needed to use back in any production process.


Some supporting documents:


Q.6. Are there are any circular economy measures which could be introduced easily by the Government to rapidly improve how we manage and minimise e-waste? Reforms that could be considered ‘low-hanging fruit’?


There is numerous low-hanging fruit that could be addressed to improve how we manage and minimise e-waste.


1. Celebrate and showcase what is already being done to show different types of business models that currently exist. Circular supply chains (e.g. Method), resource recovery and recycling (e.g. Islabikes), building products to last (e.g. Dualit), sharing platforms (crowdshipping e.g. Hitachi Transport system or Uber, homeswaps).


2. Alter the language attached to waste management. For example, the National Recycling Awards currently includes projects that are promoting circular economy models e.g. zero waste, commercial and charity partners to reuse and redistribute products before they end up in the recycling trajectory.


3. Incentivise more return and deposit schemes – as indicated in answers to question 5 above.


4. Review metrics and measurements to ensure they enhance what is currently being reported by private, public and third sector organisations. Include targets for reuse, although consideration needs to be made regarding the administrative impact of further reporting. For example, some research indicates that there is a need for integrating reports rather than requesting new ones.  Look into the financial and sustainability space.


5. Crowdsource and facilitate the sharing of best practice – Manufacture2030 Hive is a good example of how manufacturers are coming together to share insights and practices on effective resource management - invest in something similar in the e-waste space.


I feel a quick win is openly supporting the Right to Repair principles and widening the scope to other products, for example ICT equipment. I believe this to be missing – but recognize that depending upon age, this is a high value product. One other area of challenge is software, often the components of our technologies are still operational, but the software has become obsolete.


Supplementary resources:




Q.8. Are there more fundamental changes to the way companies design or gain revenue from products that the Government could consider incentivising?


Support the development of greener technologies and their Lifecyle.  For example,organic electronics - these products have flexibility and printability qualities, use fewer raw materials and have lower toxicity resulting in products that are greener more sustainable, can be biodegradable and/or recyclable or appropriate for environmentally friendly disposable. Our research indicates that there appears to be a lack of investment and infrastructural support in the UK which encourages the creation of organic electronics at scale and markets similar to those emerging in Asia. Examples, of this type of product include LED lights, display screens and in health care applications.


In addition, in a similar way to encourage a % of recycled plastics to be present in the production of new single use plastics, the same policy could be adopted for the electrical and electronic manufacture – given than on average 20% of the products are made up of plastics.


Some supporting resources:



Q.9 How effective could the use of ‘modulated fees’ in an Extended Producer Responsibility scheme be in incentivising EEE products to be designed in a way that enables easier reuse, repair, or remanufacture?


To adopt a modulated fee system further clarity is required about what is classified as sustainable design, production and procurement. This is particularly the case if the plan is to reward, or penalise producers who do not meet the requirements, as outlined in the HM Government ‘Our waste, our resources strategy’. 


Research indicates there are other alternatives that could be considered, such as:


  1. Incentivise the use of secondary materials, bio-based resources and rare earth metal substitutions.  – some virgin materials are still cheaper than alternatives (see question 4a). e.g. taxation opportunities to encourage the use of x% of secondary materials/recycled materials as has been discussed for plastics.
  2. Further support standardisation of common component parts e.g. plugs, cables, chips.
  3. Invest in the infrastructure to support those operating in the collecting, sorting and separating EEE. With product design being commercially sensitive this could encourage expansions in in-house repair and impact upon recyclers, charities etc.


Supporting documentation:



Authors biography:

Dr. Alison Stowell is an Associate Director for Lancaster University’s Research Centre, the Pentland Centre for Sustainability in Business and Social Scientists. She brings more than 10 years’ experience of research in societal and management responses to waste; waste policy; values attributed to waste and waste as a particular type of work (collection, repair, reuse, recycling). During this time, she has been focussed upon electronic waste, but more recently her interest has broadened to other complex forms of waste handling. She has worked on various electronic waste related projects - gathering insights from the UK, Japan, China, and more recently Ghana. In the last year she has been working on interdisciplinary projects ranging from attempts to quantify e-waste to exploring unreported e-waste flows, including the business and societal implications involved in flexible electronics. Prior to becoming an academic she worked in both the public and private sector for 13 years and it was whilst at IBM her interest in waste, and more specifically e-waste was galvanised.


Alison Stowell                            18th April & 28th April 2020