Towards Improved Information Exchange for Safe and Effective Treatment of E-waste


Waste electrical and electronic equipment (WEEE) is receiving increasing attention worldwide and policies such as the European RoHS and WEEE Directives have been introduced in response to the problems associated with the treatment of this waste stream. The current study investigates how relevant information on substances in products can be generated and provided to actors involved in the end-of-life treatment of WEEE. The rationale is that improved knowledge on the material composition of the items to be treated (including both hazardous substances and valuable materials) can make recycling and waste management operations safer and more effective. This requires that the information is available on a suitable format, tailored to the specific needs and circumstances of each actor.

1. Purpose
Electronic products are complex and the number of materials used in a single item can be very large. Modern electronics can contain more than 60 different elements of the periodic system and the total number of substances used in these products is of course much larger [1]. Some of the materials commonly used in electronics are valuable resources – such as gold, copper and silver, while others – such as lead, antimony and beryllium – are hazardous. This combination of valuable resources and hazardous substances is a challenge for the recycling process.

A number of earlier studies have found that the recycling industry for electronic products lacks information on the composition of the items they are treating [2-5]. It is expected that by improving the information exchange between producers and recyclers, the recycling operations could become safer and more effective. The current project therefore analyses how information on substances contained in electronic products is generated, transmitted and used by actors at various stages of the product life-cycles. More specifically, the project analyses the information exchange between the up-stream part of the life-cycle, including manufacturers of consumer products and their supply chains, and the down-stream part, including recyclers and waste managers. By analysing the current information management system and exploring the need for information at various life-cycle stages the project hopes to be able to give recommendations on how systems for improved information exchange can be designed and implemented. The project also aims to identify what additional measures (legal, administrative, logistical etc.) would be needed in order to make such information systems fully effective.

This paper reports the results of the first year’s research of a three-year project which started in the summer of 2008. So far, the project has analysed in-depth the current situation on recycling and information exchange in Japan and carried out preliminary investigations on Korea and China. In addition, the current situations in the EU and the United States have been surveyed. The empirical research in Japan consists of document analysis and face-to-face interviews with representatives of the recycling industry, electronics manufacturers and industry associations, and other experts. These investigations concentrate mainly on the following tasks: (1) Mapping in detail the recycling chains and identifying the actors involved, (2) Clarifying the current situation concerning availability and needs for information on the composition of the products at different stages of the recycling chain, (3) Analyzing the effects of existing systems for product information management, and (4) Exploring what additional measures would be needed in order for information systems to actually contribute to safer and more effective recycling operations.

The project covers information related with both hazardous substances and valuable materials. The starting hypothesis is that the flow of information on these two groups of substances is currently insufficient and it is assumed that an improved information exchange could have environmental as well as overall economic benefits. More specifically, the project assumes that a system which provides information on the composition of electronic products to the post-consumer stages could ideally have the following benefits:
- Safer recycling and waste treatment operations. Improved information on hazardous substances, including which components contain such substances and how these components should be handled, could lead to safer treatment of the end-of-life products and better protection of workers’ health and the environment.
- Higher overall recycling ratio. With the availability of precise information on the composition of products (amounts and location of each material/substance) it is assumed that a larger number of materials could be recycled and that the recycling ratio for some materials could be increased.
- Higher use value of recycle materials. With better knowledge on what substances are used in the products, it is assumed that the recycling operations can produce secondary materials which are less contaminated. Such materials would have a higher value than current secondary materials since they could be used for a wider range of applications. Even in cases where the quality of the recycled materials cannot be improved, it might be beneficial if the recyclers are able to better specify the exact quality level of these materials. With better knowledge on the quality of recycled materials, parts manufacturers could more easily decide for what applications these materials are suitable.

2. Results
The research carried out in the first year of the project confirmed that the recycling industry needs more information on the products they are treating. Especially among the SMEs, there is a need for additional information on hazardous substances and how to prevent risks when handling products and components containing such substances. The whole recycling industry reports a need for increased availability of information on recyclable materials, especially rare metals. This section presents the main findings of the investigations carried out in the target countries.

2.1 Japan
Japan has recycling legislations based on Extended Producer Responsibility (EPR) which cover PCs and large home appliances used by private consumers. These laws require the producers to take back and recycle the end-of-life products. To meet this requirement the producers have formed two consortia which handle the administration and logistics. One of the consortia has chosen to contract existing recycling companies, while the other has built its own recycling facilities. The laws do not require producers to provide any specific information to the recyclers. However, there are several initiatives aiming at improving recycling through improved access to product information.

A number of labelling systems for information sharing with recyclers have been introduced in the last few years for large household appliances. These systems have been developed by an industrial association for electronics manufacturers (AEHA) in consultation with some recyclers. The use of the systems is voluntary, but the initiative has a strong backing from the major manufacturers, and the systems currently seem to be widely used. The following systems are related with the composition of products:

(1) Marking of plastic components, indicating polymer, filling materials, plasticizers, flame retardants, and the use of recycled polymer.
(2) J-MOSS orange mark and green mark, indicating the presence or absence of certain hazardous substances (the green mark indicates that the product complies with the EU RoHS Directive).
(3) Marking indicating where compressor refrigerant can be removed.
(4) Label indicating the presence of absence of certain substances (mainly metals) in printed circuit boards, and the composition of solder.
(5) Label on equipment with built-in rechargeable batteries.

Since these systems have recently been introduced, recyclers still have no experience in dealing with labelled products. It is therefore difficult to evaluate how useful they would be in practice. What can be done currently is thus just to discuss in general terms how these labels could influence the recycling operations.

It is clear that some of these systems, such as (3) and (5) above, can be used directly at the dismantling stage, which is the first step in the recycling chain. There they can save time and reduce the risk that batteries continue to the next step of recycling, which usually involves shredding or grinding the dismantled components into small fragments. Label (2) could be used in the same way – to avoid that products containing hazardous substances are shredded – but it is harder to see exactly how the recyclers would handle these products. Since there is no information on where in the product the hazardous substances are located, or how those parts can be removed, the recycler would need to have a separate treatment route for these items in order to avoid contamination of the shredded materials and possible exposure of operators to hazardous dust.

Marking (1) could be used at the dismantling stage to sort different kinds of plastics. Mixed plastics have low use value and would in the case of Japan usually be incinerated. This marking system could therefore lead to a higher recycling rate if the sorted fractions can also be handled separately at the later stages in the recycling chain. In order to be effective, this would probably require some logistical changes.

How marking (4) is going to be used is less clear. Printed circuit boards are normally treated in integrated smelters. These facilities are capable to treat complex mixes of metals and more than a dozen elements can be recovered at high rates. The presence of hazardous metals, such as lead or mercury, is normally not a problem for these processes. However, before entering the smelting and refining processes the circuit boards have to be shredded into small pieces. At that stage hazardous substances could be emitted. However, it is not likely that recyclers will have two parallel treatment routes – one for boards containing certain hazardous substances and another for other boards – so it is hard to see how this information would be used in practice and what benefits it would have.

In addition to these formalised systems for information provision, it should be noted that many Japanese electronics manufacturers have close links to recycling companies. At least one of the major manufacturers regularly holds meetings with recycling companies where product design and recycling practices/technologies are discussed.

A Japanese industry consortium (JAMP) has recently developed an information system which facilitates the information management for chemicals in the up-stream part of products’ life-cycles. This system is a response to the REACH regulation and it aims to help companies meet their obligations under REACH. Nevertheless, the information provided by the system seems to be a potential input source for the further development of information system targeting end-of-life treatment. However, since the development of this system is driven by the chemicals regulation, it only contains data on certain hazardous substances and provides no information on rare and/or valuable metals.

2.2. The European Union
In the EU, the WEEE Directive entered into force in 2003. This Directive, which is based on the principle of EPR, sets targets for collection and treatment of a large number of electronic products and makes producers or importers responsible for carrying the costs for recycling. It also requires producers to make information needed for recycling available to the recycling industry. It states that: “producers [shall] provide reuse and treatment information for each type of new EEE put on the market... This information shall identify, ..., the different EEE components and materials, as well as the location of dangerous substances and preparations in EEE.” [6]

Although the EU legislation requires information sharing with recyclers, it has so far not been a priority for the public authorities of the EU countries to specify how this information disclosure should be carried out and what information should be included. The regulators seem to assume that there is a demand for information from the recycling industry and that requests from the recycling companies will determine what information is made available and in what format.

Manufacturers have taken different approaches to fulfilling the information requirement. Some of them have developed datasheets with recycling information and made these sheets available on their websites. In some cases these sheets also include details on the recommended disassembly process, supported by photos. In a few cases, the recyclers need to submit a registration form in order to get a user ID and a Password to access the information. There are also manufacturers that request recyclers who want information to contact them by email.

Four industrial associations have issued a joint guidance document on what efforts they find reasonable to require of producers. It recommends that:
• “Each producer creates an access point [on the internet] for recyclers to post questions in relation to his products, …”
• “A producer, upon request from a recycler …, provides information on ‘positive presence’ of [hazardous] materials and components …, at product level or product family level. Other questions will be handled on a ‘reasonable effort’ mode. The common dialogue language is English.”

In addition, the joint guidance document contains an annex listing hazardous materials and components which should be included in the information provided to recyclers. It is also stated that producers “may look at the possibility to organise dialogue between producers and treatment operators…”.

Also some consultants have developed information sharing tools which are related with the requirements in the WEEE Directive. Such tools include the “Recycling Passport,” which is currently used mainly by some small or medium-sized European companies. The Recycling Passport is a flexible format which can contain more or less information. A typical application is a PDF-document of 3-5 A4 pages containing a list of the major materials used in the product, the amount of each material, the location of any components containing hazardous substances, and some photos or drawings helping to identify these components. There is also a related German standard, a so-called technical rule, called PAS 1049 “Transmission of recycling relevant product information between producers and recyclers - The recycling passport”. However, this standard seems not to be widely used.

Compared with the Japanese marking systems for home appliances, the European systems in general contain less information. In particular, detailed information on plastic components (additives and the use of recycled polymers) and on hazardous metals in circuit boards is lacking.

2.3 The United States
In the US there is no federal law mandating recycling of electronics or to make the producers responsible for the end-of-life treatment of their products. More than a dozen individual states have recently introduced recycling regulations, but these regulations differ by state and the producers are facing a patchwork of requirements. None of these state regulations require producers to provide recyclers with product information.

In the US, the eco-labelling scheme EPEAT, which currently covers only computers, includes criteria related with information disclosure for safe end-of-life treatment. This scheme is quite widely used, not at least for public procurement, and it therefore has significant influence on the industry. Likewise, a couple of certification systems for recyclers are currently under development. To comply, it is expected that recyclers will have to increase their efforts to keep informed on the changes in composition of products and to develop appropriate and safe treatment methods.

So far, the project has not investigated how US producers convey information to recyclers or the nature of that information.

3. Discussion
It is clear that increased availability of product information from manufacturers will have only a limited effect unless efforts are made also to increase the demand for such information. In this respect, the development and effective dissemination of information on safe technologies and practices among the recyclers is needed. In addition, environmental and health regulations for the recycling industry may also need to be strengthened. In this context, SMEs may have special needs for capacity building. In order to improve recycling it is important to increase the awareness among the recyclers on hazards to human health and the environment, and on the significance of rare metals recycling, to stimulate their demand for product information, and to increase their knowledge on how to act on such information.

The information sharing tools identified in this study focus mainly on hazardous substances. This is in contrast with the results of an interview survey of Japanese recyclers which indicates a demand for information on rare and valuable metals. There are several possible explanations behind the lack of information on these materials. For example, producers of consumer products do not always have complete information on the exact material composition of all parts and components. This information is only available from their suppliers or from other companies further up the supply-chains. In addition, information such as the use of rare metals in electronic components can be sensitive for commercial reasons.

It is interesting to observe that Japan, the EU and the US have taken different approaches to information sharing with e-waste recyclers. While the EU has chosen to mandate information disclosure through legislation, the US relies on market-based initiatives handled by non-governmental organisations, but often supported by the federal EPA. In Japan, there are no such formal mechanisms in place, so that information exchange between producers and recyclers happens on a voluntary basis.

There are some crucial differences between the producers of electronics and the recycling companies. Many producers are very large and have considerable resources for generating and managing information, while the recyclers, many of which are SMEs, have relatively limited capacity in this respect. The producers, especially the big global companies, are more exposed to market demands for environmental improvements and are therefore more active in analysing and reducing their environmental impacts, often from a life-cycle perspective. Recycling companies operate in a different market environment and therefore feel less pressure for environmental improvements. Many recyclers seem to assume that the environmental and health risks are negligible as long as they comply with the laws and governmental regulations. In contrast, many producers feel a need to be more proactive and go beyond the existing legislation. This underscores the need to also stimulate the demand for product information among recyclers.

Different stages of the recycling chain have different needs for information. For example, the information needed for safe and efficient disassembly is not same as the information needed for the recovery of precious and rare metals from printed circuit boards. Furthermore, information provided by the producers may only be accessible at the disassembly stage; after a product has been disassembled it is usually not possible to identify from which type of product and from which brand the different parts come. For this reason, it may be needed to develop information sharing systems consisting of two separate components: one for information from the producers to the disassembling companies and another for information from the disassembly stage to the following stages of the recycling chain. The design of these two systems and the information contained may need to be different.

In addition to providing relevant information to the recyclers, it is also important to improve product design. Design changes can make recycling easier, safer and more effective. However, in order to be able to make the right changes electronics designers need to know more about how recycling is done and what problems the recyclers are facing when treating the existing products. Feed-back from the recyclers to the manufacturers is therefore another key element towards greener electronics. However, this aspect of the information exchange is not covered in the present study.

Another topic which has not been dealt with in the first year of the project, but which may be addressed in later stages, is the information needs for reuse of electronic components. When an electronic device reaches end-of-life it still contains many components that are fully functional, some of which could be beneficially reused. This happens to some extent in developing countries, but on any significant scale in the industrialised world.

Finally, it should be pointed out that from a global perspective the really severe problems associated with e-waste are caused by inappropriate recycling carried out in developing countries. These unregulated, and in some cases illegal, activities are causing serious pollution and threatening the health of large numbers of people. Although the availability of information on hazardous substances in electronics is a basis for developing safe treatment methods, to develop solutions on how to address these dangerous activities is a task which goes beyond the scope of the current paper.

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[6] Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE). Brussels: European Commission.