Producer Responsibility

NVMP Association

» Management Summary
» Introduction
» About manufacturer responsibility
» About e-waste
» About the chain
» About financing
» On monitoring and enforcement
» About the awareness of consumers and Wecycle
» About research and development
» About tomorrow's NVMP
» Downloads


Management Summary
The NVMP Association, collective advocate of six product foundations will spend the next ten years focusing on the following five objectives:

  • Improving the implementation organization
  • Maximizing the collection volume
  • Investing in collaborations within the Netherlands
  • Becoming the ultimate Knowledge Institute
  • Expansion of international relations

In order to achieve these objectives, the Association shall use the Wecycle which is the operational implementation organization of the product foundations. By achieving the above-mentioned objectives, NVMP wants to reach both domestically and internationally acknowledged market leadership in the field of e-waste collection, transportation and processing.

This is only possible when it is acknowledged that all participants (collection systems, processors, logistics, consumer, municipalities and manufacturers) bear the joint responsibility of ensuring that e-waste ends up in the appropriate channels and that the collection volume is maximized. A good partnership between municipalities and retail is of great importance and e-waste needs to be subject to a performance fee. In addition it is of the essence that we provide a high service level, transparent business and an above-average information provision to our participants (manufacturers/importers and retail).

Partnerships with similar collection systems in the Netherlands will be observed, in order to reap the benefits of synergy and to expand knowledge.

Through, current research and knowledge will be made accessible to comparable collection systems, the government and a broad range of societal stakeholders. Moreover, additional domestic and international research will be initiated to remain informed about the latest developments in the e-waste industry.

Investing in contacts with collection systems will become increasingly important to be able to better respond to market changes and legislative changes from Brussels.

As an organization, the NVMP wants to be a role model with regard to socially responsible entrepreneurship.

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The NVMP Association is the collective advocate of six foundations that are directly involved in the regulation and legislation in the field of Waste Electrical and Electronic Equipment (the so-called WEEE-Directive). The manufacturers and importers of electrical and electronic equipment have been united in these six foundations.

We aim to collect and recycle equipment marketed by our participants as good as possible, after it has been dismissed. In most cases, we go way beyond what the government prescribes. For collecting and recycling is not just a matter of producer responsibility, but mainly of socially responsible entrepreneurship.

With that in mind, our mission is very clear: the volume of dismissed equipment collected, needs to increase. That is the challenge we address. In this brochure you can read about how we go about this, and what our vision is with regard to the way this is best achieved – now and in the future.

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About manufacturer responsibility
Producer responsibility means that producers and importers are (co)responsible for the management of products marketed by them, even at the waste stage of these products.

Three factors are essential with regard to the structure in which collection and processing occurs:

  1. The product foundations that collectively determine the details of the producer responsibility for one or several products. These are: Stichting FIAR CE (brown goods), Stichting ICT Milieu (ICT), Stichting LightRec Nederland (lamps and lighting), Stichting Metalektro Recycling, Stichting Verwijdering Elektrisch Gereedschap (power tools) and Stichting Witgoed (white goods);
  2. The NVMP Association, in which the product foundations combine their interests and jointly promote these;
  3. Wecycle which is the operational implementation organization of the product foundations. This implementation organization takes out contracts with national and international transporters and certified processors on behalf of the product foundations, and monitors the quality.

The manufacturers and importers aim to collect as much dismissed equipment as possible. This means that they want to exceed the targets set by the environmental policy and the regulations. However, the collection target may vary for each product foundation. This is related to the costs of the collection method and the efficiency thereof. For business reasons, it’s not logical to always achieve maximum collection at any cost. In other words: it’s also about a healthy consideration between ecology and economy.

Collectively or individually?
Producer responsibility can be interpreted collectively or individually. The manufacturers and importers that are united in the NVMP Association have consciously chosen a collective solution for several reasons.

For starters, all discarded products, regardless of brand or age, are disposed (collected and recycled) in a collective system. This also includes brands that currently don’t exist anymore or of which the original market participant is no longer active in the Netherlands. Individual (proprietary) collection does not have these advantages.

In addition, a collective approach leads to more clarity and a better realization of the social objective. Since every participant in the chain deals with just one party, manufacturers can learn from experiences with the different technologies applied to the products, and the processing thereof.

Finally, cooperation leads to the biggest net return, due to economies of scale. A collective system turns out to be the most effective and efficient approach, both for the consumer and the manufacturer. An approach that leads to the best possible result at the lowest possible costs, as shown by research conducted by PriceWaterhouseCoopers in 2001.

In addition, the current WEEE Directive and the implementation thereof in Dutch legislation has also been modeled based on a collective solution; the entire legislation and regulation has been written in the collective mindset.

Why no individual responsibility?
In some countries, companies are more in favor of Individual Producer Responsibility (IPR), since it can be deployed as instrument in the competition between companies. Even NGO's such as Greenpeace are in favor of IPR since it leads to producers feeling responsible for their own E-waste that is reflected, for instance, in more design for recycling (DfR).

DfR in itself is an important socially responsible entrepreneurship principle that is widely supported by the manufacturers. However, the European Union has separate legislation for DfR: the ROHS- and EuP Directive. In addition, there is no or hardly any direct correlation between dismissal and design. This is why NVMP believes that the DfR principle can’t be part of a disposal system: design and recycling are two ends of a chain, separated by many years of use. For instance, the equipment that we are processing today, was designed fifteen years ago, according to techniques that were common at that time. These products come back from the market in a very diffuse composition, only to be processed according to modern-day techniques. The chance that large amounts of one certain brand are processed at the same time, is very minimal. In addition, the designs that are present in the Netherlands often aren’t determined by Dutch manufacturers, but elsewhere (for instance in Asia).

IPR comes with the big risk of a manufacturer feeling exclusively responsible for his own products. With regard to orphan brands (these are brands of which the manufacturers and / or importer is no longer active in the Netherlands) choosing for IPR alone, would lead to the inevitable consequence of these orphan brands not being processed at all or the government bearing the burden of processing these brands. In the collective system of NVMP these orphan products are collected and recycled as well. Moreover, an individual manufacturer has little to gain from a maximized collection volume. After all the costs increase as he collects more. In a collective system, the costs are equal to every manufacturer.

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About e-waste
E-waste is all equipment that the consumer - in professional terms, the disposer - decides to offer for recycling, be it separated or not. Therefore, waste is only considered e-waste when the final user dismisses the equipment. Prior to this final user, there have often been other users, for instance through second-hand trade. Electronic items that arrive at a specialist shop for recycled goods are not considered to be e-waste, for instance. In the Netherlands, household waste is, in most cases, collected by the municipal waste departments. In addition, more and more people bring their old equipment to the retailer when buying new equipment, and more and more disposers leave their equipment at the retailer if repairs turn out to be too expensive. In addition, there is also a circuit of informal collection, for instance by ‘morning stars’. This ‘first collector’ – retailer, municipality, informal collector – will largely determine the further route the dismissed device will travel.

The manufacturers and importers are willing to collect and process this E-waste for a fee: they are the ‘second collector’. If the first collector chooses not to provide the e-waste to the manufactures, being the second collector, this obviously has a strong negative impact on the responsible processing thereof. In that case, it’s possible that the E-waste will only be partially processed, while the rest is dumped, or even exported in an undesired or even unlawful manner.

Therefore, an effective and responsible disposal by the manufacturers largely depends on the other factors: are the first collectors taking their responsibility? If the disposer chooses to throw the device in the waste bin, environmental processing is near impossible.

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About the chain
The life cycle of electrical and electronic equipment is of a completely different nature than that of a newspaper, for instance. Whereas a fresh newspaper ends up in the wastepaper bin within a couple of days, many years pass before most newly purchased electrical and electronic equipment is dismissed as e-waste.

The manufacturers and importers united in the NVMP Association have a clear vision with regard to this long chain of production - use - dismissal - collection - processing.

Production of electrical or electronic devices does not or hardly occur in the Netherlands anymore. However, in the production of these devices, principles such as Ecodesign, Design for Recycling and Design for the Environment are increasingly central. These principles are aimed at designing devices that cause less emission, lower use of raw materials and less energy consumptions during the production, the use phase and after dismissal. Devices are often designed in the country where they are produced. The Dutch importers have little influence on the design and the production. In addition, the Dutch market outlet is too small in the world market to be able to enforce this. Still, the role of the Dutch industry isn’t to be erased. For instance, lots of research is being done into better collection- and processing methods. This knowledge on dismissal, collection and recycling is made available to manufacturers and other interested parties on a regular basis during the symposiums and congresses, partly due to the efforts of the NVMP Association.

Consumer responsibility: purchase, use and dismissal
The consumer has an important personal responsibility with regard to achieving environmental targets. This starts with the purchase of new products; by purchasing energy efficient and / or sustainable equipment, the consumer directly contributes to a better environment. That contribution may be increase by using those devices in an effective and efficient manner. At the end of the life cycle of a device, this responsibility pops us again if the consumer delivers the dismissed product to a responsible and transparent collection system (whether or not municipal).

Collection: from coarse to finely meshed
NVMP aims to transport as much equipment in logical, meaning large quantities. This is why, at the municipal environmental agencies, you’ll find containers in which various products can be deposited. This often occurs in a separated manner: fridges with fridges and TVs with TVs. The containers are taken straight from the municipal waste departments to recognized recyclers. In some cases, pre-sorting isn’t possible. In that case, containers that contain several types of products are transferred to a Regional Sorting Center. In addition, large quantities need to be collected as well, for instance at the local retailers. To this end, finely meshed collection is used; every store saves up a number of devices, which are collected by request.

Complementary flows
In an ideal situation, a device that has been permanently dismissed, is delivered to a store or municipal waste department, to be passed on to a recognized collection system such as that of NVMP or a NVMP recognized recycler. In addition to this ‘primary flow’ other routes are also imaginable: the device ends up with other collectors or ‘morning stars’ or in the worst case: in the waste bin.

If devices are collected by collectors other than NVMP (or other recognized systems), this is called complementary flows. These are only legal if the Dutch or European waste legislation is complied with. If not, it concerns illegal complementary flows, or leak flows. A common example is ‘cherry picking’, in which the collectors only collect the valuable (parts of) goods and then dump the undesired parts in an unprocessed manner. In those cases, the required reports often aren’t met.

The NVMP is very active in mapping these complimentary flows, in order to paint a good image of any leak flows and the way these can be countered. However, this requires very extensive research to find out if it involves reuse or that it concerns a form of waste disposal. The latter is odious, obviously, however, if it involves reuse it is also considered to be a missed opportunity. After all, NVMP accepts all e-waste free of charge and processes it in an environmental friendly manner, whereas in case of product reuse, the, for instance, African end users end up with products that are relatively environmentally unfriendly. Moreover, second-hand equipment will fail as well someday; however, at that point it’s in a country that doesn’t have a proper collection- and processing system. Many of these devices end up at landfills, which means that both the harmful environmental aspects and the waste problem have been exported. In those cases, the original manufacture is often wrongfully addressed with regard to its responsibility.

Responsibility up to the front door?
In December 2008, the European Commission submitted proposals for the revision of the WEEE Directive. In those proposals the manufacturer responsibility is explicitly extended to the front door of the consumer. The same idea is behind the new National Waste Management Planning 2 (Landelijk Afvalbeheer Plan 2). This means that the manufacturers and importers are held responsible for all collection and processing costs – even those incurred by municipalities in the environmental field.

Anticipating the new legislation and in line with the socially responsible entrepreneurship strategy, the manufacturers and importers currently pay municipalities an amount of EUR 79 for each ton of unsorted e-waste. This covers the costs and is in line with the rates that apply in other European countries. This amount also includes the registration, which will finally lead to a good picture of how much e-waste there is in the Netherlands and how or where it is recycled.

With regard to processing, NVMP uses recognized and specialized recycling companies, contracted by means of a tough tender procedure. Processing locations are distributed throughout the country (and just across the border) so that unnecessary transport is avoided as much as possible. Every year, the processors have to account for the amounts supplied and the disposed reusable raw materials; this occurs based on a so-called mass balance. These details are audited by an accountancy office and reported to NVMP, and subsequently to the Dutch Ministry of Environment (I&M). The contracts include a clause which states that compensations depend on the applicable market prices of the reusable raw materials.

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About financing
There are several options with regard to financing the disposal costs. The two main options are passing on the costs to the consumer directly or indirectly. If the direct variant is chosen, the consumer will have to pay a separate visible removal fee on top of the product price. In case of the indirect variant, the costs have been discounted in the product price. When creating the NVMP system, the direct financing system was chosen in the form of a visible removal fee. An important argument thereto was the large historic stock at that time. The processing costs turned out to be unaffordable with respect to the product price, or at least not without profitability being seriously affected.

However there are more good reasons to use a visible contribution. For instance, the visibility of the removal fee increases consumer awareness with regard to the environment. No margin is realized by the intermediaries due to the external and visible removal fee. If the costs would be internalized, they would be part of the normal calculation schedules and they would be part of the profit. The final price tag would be higher, the price would be fattened. By externalizing, that fattening process does not occur.

It seems as though the revised WEEE Directive allows for a continuation of the visible removal fee. Due to this, the communicative aspect remains in effect but at the same time a level playing field for manufacturers can be guaranteed more easily. On the other hand, differentiation may be possible based on differences in environmental taxes for products, to meet the demand for IPR. However, this may lead to additional administrative burdens.

When the disposal system commenced in the Netherlands (1999), there was a huge ‘installed base’ of devices. Devices that, at that time had often been used for a long time. This is called ‘historical stock’ in legislation; the professional term for it is ‘Altlast’. This large volume of devices worked as a ‘mortgage’ at the start of the activities of the product foundations. After all, they have taken on the responsibility of cleaning this Altlast as well. The current financial capacity of the product foundations currently (July 2009) is still insufficient.

Neulast involves devices sold after August 2005. With regard to financing these costs, the current legislation doesn’t allow for the use of a visible removal fee. However, in the design text of the revised European legislation, this possibility has been included. In the financing system for Neulast, a management fee will be charged starting January 2011 instead of the removal fee. With regard to this, it is important that the management fee remains constant so that the consumer costs remain the same. The financing system for Neulast prevents participant provisions; after all these are managed by the collective, the product foundation. The third objective consists of gradually reducing the current large provisions that have led to social discussions to date.

Deposit not desirable
A deposit is not a form of funding, it’s just a means to support the collection. Deposits require an immense administration, participation of every outlet and of all locations that accept e-waste, even if these locations are not stores. This is why, for instance for bottles this was initiated in the form of a mandatory regulation of a branch. However, a deposit should be a stimulus that is in proportion to the effort. With regard to bulky e-waste, this would lead to a considerable amount per product. In addition, deposits are based on a reasonably fast turnaround, and in general, this is not the case with electronics. Deposit leads to a large inert seizure of financial resources. Moreover, a deposit system is very fraud sensitive without a solid means of identification.

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On Monitoring and Enforcement
Responsibility also implies accountability. Ever since the introduction of the systems, the NVMP is accountable to the Dutch Ministry of Environment (I&M).
This is done both with regard to the collected and processed amounts, and the financial field.
Ever since the Financial balance sheet over 2007, NVMP pursues even more transparency, by improving the legibility of the balance sheet and providing clear explanations that are comprehensible to every reader. In addition, all product foundations will publish their balance sheets on the internet from now on.

For proper monitoring by the I&M Ministry, a conclusive administration is also required with regard to the e-waste passed on to the systems. The flows of e-waste that move outside of the systems (leak flows of e-waste mixed with other waste flows, whether or not intentionally) can not be subject to administration due to the nature of the case. Initially, the ministry itself is responsible for a reasonable measurement of these flows. However, if the manufactures are legally obliged to collect a certain percentage of the (new) sales, the situation will change considerably.
Currently the participating manufacturers/producers provide the numbers of their (new) sales once every few years. Based on this, the weight of the marketed products is derived. This will probably have to change in the future due to the toughened collection targets of the revised directive: both the numbers and the weight need to be provided. In addition, collective objectives need to be achieved that are related to the (new) sales. This is only possible when subject to a significant expansion in monitoring.
Currently, the systems are regularly investigating how much equipment is present in the market and what the dismissal behavior of end users is. Partly based on these investigations, the destination of the e-waste is determined. It is probable that this investigation should be expanded after the revision of the legislation. After all, without a responsible measurement, there can be no performance justification (measuring is knowing).

Producer responsibility requires measures that consume time and money. Dodging that responsibility seems beneficial on the short-term since no funding needs to be arranged and no administration needs to be maintained. The current system was created years ago by a limited number of companies, only to expand to hundreds of participants per foundation in a matter of years. In some cases, coercion was exercised by the environment inspection, which made so-called free-riders join the system. Currently there are hardly any free-riders. The once that emerge are often new participants in the market or companies in the margin of the market. The last category in particular may invoke a lot of frustration with the participants, since they often have an unlawful competitive advantage. However, this group in particular is hard to deal with without a body that has espial authority.

NVMP has no authority with regard to enforcement and has no aspirations in this field. This is why she can only issue warnings. For the internal enforcement of regulations and the specifications agreed on within the system, the systems can only record by contract if and how enforcement occurs. This applies to both logistic partners and processors, who work with an audit schedule. In European context the WEEELABEX project of the WEEE Forum was developed (the international partnership of collection systems, founded partly by NVMP), which sets both processing standards and standards for management support. With regard to this it is essential that a uniform automated system is introduced at the processors, for monitoring the flows and fractions. This so-called Reptool software was developed by commission of the disposal systems and allows for accurate measurement of processor performance.

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About the awareness of consumers and Wecycle
It’s clear that communication plays an indispensable part in the creation and development of a disposal system of the currently achieved size. Apart from the internal information provision (to participants, retailers, municipalities and processors) communication with the end users is of the essence.
The first form of communication consisted of the introduction of the visible disposal fee: after all, at every purchase, the buyer was directly confronted with the fact that in time, the purchase would be discarded. This primary psychological and communication effect is not to be underestimated. In addition, the purpose of this levy required an extensive explanation and information needed to be provided about what happens to the product after it has been discarded. This information was provided in the stores, but was also supported by mass-media. In the first nine years of existence of the disposal system, millions have been invested in awareness campaigns. Due to this, recent polls have shown that awareness has increased to about 98%, pretty much the maximum of what can be achieved.
However, awareness in itself is not enough. Consumers generally know what to do with a discarded device, but do not always act accordingly. Small devices in particular, are disposed of through the waste bin, and do not end up in the recycling circuit as a result. That is why two large target audiences remain as a focus of the communication effort, being: the end users and the municipalities as collectors. The multi-year campaign focused on this is implemented under the name Wecycle.
In addition, NVMP wants to research how new media can be deployed and current media can be improved, for instance with ‘viral marketing’ deployed by the Stichting Batterijen.

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About research and development
Research, information provision and actions aimed at behavioral improvements of disposers and processors, are part of the collective NVMP-system. Manufacturers, for instance, gather design suggestions, so that products are easier to process at a later stage. But they also launch initiatives that help them share the knowledge with the global regions, still involved in the creation of systems for collection and disposal. Examples are the special research program at the TU Delft, the support of the University of the United Nations and projects in other countries, such as Cyprus, Romania and Bulgaria (in the past). In 2009 and 2010, new research has been planned, including in West-Africa, but also research into complementary flows in the Netherlands. In addition, the research into processing techniques is expanded.

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About tomorrow’s NVMP
It’s very clear that the biggest challenges for the NVMP are in the future. That is why, in the next couple of years, manufacturers and importers want to develop Wecycle into a nationally and internationally acknowledged market leader in the field of e-waste collection. In addition, the organization is to play a prominent role as knowledge institute, not just for her participants (the manufacturers/importers and retail) but also for comparable collection systems, the government and a broad rage of social stakeholders. The message here is ‘the manufacturer is central’, the NVMP has to provide her participants a high service level, transparent business and an information provision that is above average. In addition, the organization is an example with regard to social responsible entrepreneurship in the larger context of government and non-governmental organizations.
To be able to realize those targets, attention needs to be paid to a number of themes that involve the internal performance and relations with outsiders. With regard to the internal performance, the first thing that is further improved is the implementation organization. The effectiveness of this organization needs to be secured by contracts with the participants, municipalities and retail with regard to financing, logistics and quality. In addition, one of the focus points will be the maximization of the collection amounts. Increased investments will be made in partnerships within the Netherlands and the involvement in national research will be intensified, and initiated where required. Last but not least, NVMP will further expand her international network of contacts.
New structured forms of information provision (including through the special website will not only lead to more exchange of knowledge, but also to more transparency with regard to the compensation for the collected e-waste.

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For further information: Wecycle for Dummies

» Dutch Regulation on waste electrical and electronic equipment (14 February 2014)
» Explanatory Notes Dutch Regulation on WEEE

» About the NVMP association
» Position Paper Collection criteria
» Position Paper Collection Objectives
» Position Paper Costs of initial collection
» Position Paper Deposit on electronics
» Position Paper Disposal fee
» Position Paper Enforcement
» Position Paper Materials roundabout
» Position Paper Old-for-similar-nothing
» Position Paper Provisions
» Responsible processing of e-waste

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