Principle 1: All parties in the disposal chain have 'disposal chain' responsibilities

Once WEEE has been discarded there are different routes it may take before it is reused, recycled or sent to landfill. The route involves a range of organisations, which together make up the disposal chain.

At each stage of the chain there are health and safety, quality, and environmental issues that need to be managed.

All organisations that want to demonstrate good practice standards of care should:

  • identify their role in the disposal chain (they may have more than one role)
  • ensure they have management procedures in place to manage their role effectively (in particular, to manage health, safety and environmental risks)
  • look up and down the disposal chain to make sure others in the chain are managing their impacts too. It is recommended that the good practice extends to the next operator in the disposal chain as an absolute minimum (tier 1 supplier)
  • keep data on WEEE entering and leaving their operations.

By doing this, all members of the chain are recognising they have disposal chain responsibilities.

Each member in the chain should make sure the WEEE they are responsible for is dealt with by appropriately qualified and managed companies. This ensures an element of self-regulation for the industry and reduces each party’s risk that their operation will be tainted by the inadequate performance of their suppliers.

Figure 1 shows the key stages of the disposal chain.

Figure 1:     The EEE/WEEE disposal chain

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Table 1 highlights the key areas of responsibilities along the disposal chain.

Table 1: Responsibilities along the disposal chain
Member Types of organisations Primary responsibility
Disposer of WEEE Businesses, government agencies, and household consumers disposing of their own WEEE

Councils arranging recycling of household WEEE

Producers/original equipment manufacturers/importers arranging the disposal of consumer and/or business WEEE (as part of a product stewardship scheme)
To deliver WEEE to a collection point instead of a landfill
To ensure WEEE is dealt with by appropriately qualified and managed companies
Collector Local councils

Refurbishment companies

Recycling companies

Scrap metal merchants

Waste management companies

Retailers/resellers

Community groups

Product stewardship organisations on behalf of their members

Producers/original equipment manufacturers/importers

To ensure WEEE is collected in an appropriate1 way to maximise its reuse and/or recycling potential

To keep appropriate records so the amounts of WEEE collected can be monitored

To keep an appropriate record of sources of WEEE and the recycling routes used (if they are the first processing facility)

To ensure the material is passed to a reputable2 reuse operator or recycler with appropriate management systems so all health and safety and environmental risks are managed

Reuse operator Remarketing companies

Community sector reuse operators

Other refurbishers/resellers

Product stewardship organisations on behalf of their members

Producers/original equipment manufacturers/importers

To ensure WEEE is prepared for reuse to the required health and safety and environmental standards

To keep a record of the total volume of WEEE entering the operation, and tonnages refurbished, redeployed, dismantled and sent for further processing and disposal

To ensure the recycling and disposal companies downstream are reputable

To comply with all legislation

Recycler (materials recovery) Scrap metal merchants

Recycling companies that process or resell/reuse recycled materials for new products (both in New Zealand and overseas)

Intermediaries/agents/brokers

To recover metal, glass and plastic components of WEEE following appropriate health and safety, environmental, and quality procedures

To keep a mass balance (total volume) of material in and out of the operation and provide this information to customers as appropriate

To dispose of any residual waste to appropriate facilities

To comply with all legislation

Exporter

Reuse companies dismantling equipment/components that cannot be reused

Recycling companies

Intermediaries/agents/brokers

Community groups

Scrap metal merchants

To dismantle equipment into its constituent parts to enable downstream processing and recycling

To ensure the dismantling operation meets health and safety and environmental standards

To keep a mass balance (total volume) of material in and out of the operation
To ensure the overseas recycling and disposal companies downstream are reputable

To comply with all legislation (including the Basel Convention)

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It is not enough for an individual operator to know they are acting responsibly when the equipment is in their possession. They also need to ask questions and gain assurances from other organisations in the disposal chain.

This involves establishing procedures and audit trails, which can range from a simple checklist of questions to full supply-chain auditing. The level of detail required is a judgement call based on the level of risk associated with the operation. Types of assurances include:

  • contracts
  • agreements
  • statements
  • documented processes
  • demonstrable capability
  • ongoing periodic checks
  • performance reports.

See the purchasing recycling services checklist (PDF, 194 KB) for questions to ask the next member of the chain and what to keep a record of.

Product stewardship schemes that use reuse and recycling services can establish environmental evaluation procedures for disposal of high risk commodities. These procedures should include:

  • a pre-assessment of the disposal operations and practices
  • material flows
  • business management systems.

Designated clauses can then be incorporated into service provider agreements. These agreements may require the first tier provider to ensure compliance from their providers (second tier service providers) and sub-contractors.

1‘Appropriate’ means the level of detail, for example, of records, will depend on the size of the operation and the quantities of waste treated. For example, if a company is disposing of four computers, it is inappropriate to expect that company to undertake full audits of the supply chain through to the end disposal point. However, if a company is disposing of a large amount of WEEE, it is appropriate that they operate a higher level of due diligence.

2 For the purposes of this guidance, ‘reputable’ is defined as those who can demonstrate they have exercised their disposal chain responsibilities.

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Last updated:15 March 2011