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Make European producers responsible for the management of their e-waste internationally.

Make European producers responsible for the management of their e-waste internationally.

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This petition has been created by Kaustubh T. and may not represent the views of the Avaaz community.
Kaustubh T.
started this petition to
Government of Nigeria and European Commission
Petition to the Nigerian Government and European Commission on organizing effective repair and recycling for imported second-hand Electric and Electronic Equipment (EEE) and discarded electrical and electronic equipment (e-waste): implementing Ultimate Producer Responsibility.

We welcome you to endorse this petition on implementing Ultimate Producer Responsibility (UPR)  for producers of electronic and electrical equipment that is exported from high-income countries towards low-income countries. UPR aims to reduce such exports' ecological and health impacts and create greater economic benefits associated with the transboundary movement of electrical and electronic equipment (EEE), both second-hand EEE and discarded EEE (e-waste).

This science-based petition is a product of the work of four researchers and twenty-four e-waste experts from nine countries who have co-created a concrete domestic and international action plan to add circularity and sustainability in EEE management over the past eighteen months.

The national and international solutions with specific actors and actions are laid out below:
1. We observe that:
  • Second-hand electronics enter Nigeria in large volumes, mostly coming from European countries;
  • that the treatment and refurbishment mostly takes place in an informal and weakly regulated market;
  • that the consumer use of EEE is dominated by imported second-hand EEE in Nigeria;
  • that the remaining lifetime is mostly very short;  
  • that the post-user phase collection and treatment is hardly organized, which causes severe health and environmental problems; and
  • while in Europe, producers are held (financially) responsible for proper recycling of this post-consumer EEE; however, they are not held responsible for their products that leaks to African countries.

  2.   Therefore, we recommend the Nigerian government to implement a new national circular EEE policy, explicitly focusing on this international trade of EEE by introducing an international financial mechanism while simultaneously transforming the national EEE treatment sector in Nigeria.
This includes both national and international collaborative actions.
These actions have been identified in a Delphi study with 24 experts in EEE trade and recycling in Nigeria and neighbouring counties.
Recommendations for the Nigerian government:
a.     Enable a transformation of the informal sector, active in refurbishing and reselling imported second-hand EEE, by building capacity, awareness-raising and training for specific roles that ultimately incorporate them into safe and well-paying jobs, including waste collectors and separators, repairing, refurbishing and recycling with qualified training. In this way, the government can recognize and reward the informal sector's crucial role, incorporate and empower them politically and economically, thus minimizing the health and environmental harms to their communities and contributing to prosperity.
b.     The National Waste Management Policies include an internationally oriented version of Extended Producer Responsibility (EPR), instead of the currently promoted version, which lacks an orientation towards the international trade flow characteristics of the problems of managing second-hand EEE and illicit and illegal imports of WEEE. This new form of EPR, we term Ultimate Producer Responsibility, includes a financial transfer mechanism from EU-based EPR programmes dedicated to upgrading and the final treatment of imported second-hand EEE under international standards and sustainability guidelines in Nigeria (and other African countries). This enables adding value through repair and refurbishment to extend the equipment life and establishing sound end-of-life management systems for the large volume of second-hand EEE in usage.
c.     Ensure that in the revised National Waste Management Policy, as a part of the Ultimate Producer Responsibility, a permanent monitoring program is established, identifying the original equipment manufacturers and origin countries of imported EEE and periodically reports to measure performance and goal achievement.
d.     Implement the "polluter pays principle" for imported EEE, both new or second-hand EEE, via the Ultimate Producer Responsibility. This means making original equipment manufacturers and importers responsible for contributing their fair share for extending EEE's lifetime and sound management of recycling of e-waste. A financial mechanism is created for second-hand imported EEE, sourcing funds from the EPR programs under the EU WEEE Directive 2012/19/EU.
e.     Implement a program supporting local governments in creating infrastructures for awareness-raising and collection for recycling of EEE, aiming to maximize the value of EEE for as long as possible. The local government creates infrastructures for repairs and refurbishment and facilitates the effective collection, sorting, recycling, and disposal facilities that fit the needs of the local context. The financial resources for this are to be provided under the Ultimate Producer Responsibility regulations by the original equipment manufacturers and importers.
f.     The Ultimate Producer Responsibility requires establishing a producer responsibility organization, run by the producers and importers whose actions must follow the standards set by the United Nations Convention against Corruption for transparency and corruption prevention.
Recommended collaborative actions for African countries:
a.     Countries that are receiving second-hand EEE imports from Europe to ensure a new and appropriate funding for repair or end-of-life management by original equipment manufacturers and importers be transferred along with import/export of used EEE or e-waste. Existing domestic EPR mechanisms of importing countries incorporate the Ultimate Producer Responsibility principles and connect these with the existing EPR mechanisms of exporting EU countries (under the EU WEEE Directive 2012/19/EU and Directive (EU) 2018/851) to facilitate financial and knowledge transfer for sound e-waste management.
b.     Revisit international arrangements like the Basel Convention's Decision BC-12/5 to ensure all that UEEE exports accompany certification of functionality and durability to prevent importation of e-waste in disguise or second-hand items with a short life span.
c.     Negotiate with the European Union and its member states a revision to the EU WEEE Directive 2012/19/EU that includes financial responsibility for exported second-hand hand EEE to Africa in the regulations. This is discussed in the European Parliament; see question reference: E-003034/2021 and its answer E-003034/2021(ASW)).
d.     Support the Right to Repair law and negotiate with the European Union and its member states to extend the repair rights to all consumers who benefit from second-hand hand EEE from the European Union. This collective action should make repair and refurbishment for reuse easy, accessible, and cost-effective to extend the lifespan of the European product everywhere. This action systematically tackles the problem of needless consumption and throw-way culture while promoting sustainable resource use and reducing toxic waste generation.
e.     EU member states and African countries mandate and strengthen the collaboration of port authorities of the importing and exporting countries for regular knowledge sharing, monitoring, and measuring the flows of imports/exports and its fate with greater accuracy and transparency. There should be more support for existing international bodies like the International Criminal Police Organization, the European Union Network for the Implementation and Enforcement of Environmental Law and Ports Environmental Network-Africa, who already facilitate such collaboration.
3. Rationale for the petition
The domestic consumption of EEE in Nigeria and elsewhere are increasing. Nigeria lacks a basic waste management infrastructure; handling e-waste is a significant challenge. There is also an influx of second-hand EEE in Nigeria – some of which are either non-functional (e-waste), non-durable or non-repairable (soon become e-waste). The Person in the Port Project in 2015/2016 found 71,000 tonnes of used EEE being imported to Nigeria, 77% of which arrived from the EU and 11% of it being e-waste. From our research in 2020, experts estimate 43% of all EEE used in Nigeria are second-hand, indicating a big market for second-hand products. About 35.7% of second-hand equipment are imported from Europe, of which 37.25% arrive in Nigeria disguised as e-waste. Of the remaining two-thirds of UEEE, they last only 2.3 years on average, after which they become e-waste. E-waste is hazardous and causes health and environmental harm. If managed right with proper knowledge and infrastructure, e-waste contains valuable resources and can bring financial gains. Nigeria is known as one of the e-waste hubs in Africa, where the informal sector primarily engages in collecting, repairing, and crude recycling. Although these create jobs (repair, refurbishment, resell, collection and primitive recycling etc.) and provide livelihood, unsound practices like burning and acid leaching create harm. So far, there are only a few formal e-waste recycling facilities in Nigeria. The majority of e-waste undergo crude recycling and dumping. The problem of e-waste, both domestic and imported, have created sustainability challenges in Nigeria.
4. Blueprint for the Ultimate Producer Responsibility
In EU countries with Extended Producer Responsibility (EPR), producers are held responsible for end-of-life management of Electronic and Electric Equipment (EEE). However, the EPR systems are limited inside the national jurisdiction. In reality, many second-hand EEE are traded and reused globally. Our research finds 35.7% of all imported second-hand equipment in Nigeria are from Europe, with an average lifespan of 2.3 years, after which they become e-waste. The existing EPR system must transform to make the producers responsible for e-waste generation everywhere, not just nationally. We call this transformative EPR Ultimate Producer Responsibility (UPR), which takes international trade in second-hand EEE into account and accounts for the ultimate fate of the EEE globally. UPR includes a financial transfer mechanism from EU-based EPR programmes to countries that import second-hand EEE from Europe. UPR is dedicated to upgrading and the final treatment of imported EEE following international standards and sustainability guidelines in second-hand importing countries. UPR system enables value-addition through repair and refurbishment to extend the equipment life and establish sound end-of-life management systems for the large volume of second-hand EEE usage.

To learn more about the Ultimate Producer Responsibility, please visit: https://doi.org/10.5281/zenodo.5957809
To watch the video outlining the research, please visit: https://www.youtube.com/watch?v=dUfE_eUot68

The petition has been co-authored by:
  • Kaustubh Thapa, Utrecht University, Netherlands
  • Dr. Walter Vermeulen, Utrecht University, Netherlands  
  • Dr. Olawale Olayide, University of Ibadan, Nigeria
  • Dr. Pauline Deutz, the University of Hull, United Kingdom
  • Ojo Olumide Alex, Harvest Recycling Limited, Nigeria
  • Dr. Chimere May Ohajinwa, MPHC-Circle Research, Nigeria
  • Dr. Vusumuzi Maphosa, Lupane State University, Zimbabwe
  • Cajetan Okeke, Alamonk Recyclers Ltd, Nigeria
Posted (Updated )