ENV-1 - Extended Producer Responsibility (EPR)

Product Use Case Summary

IDENV-1

Name

Extended Producer Responsibility (EPR)

Sector

Environment and Climate

Version

2.0

Status

Published

This use case provides step by step guidelines on how to implement the Extended Producer Responsibility (EPR) system of waste from electrical and electronic equipments (also known as e-waste). EPR is an environmental policy approach that regulates a producer’s responsibility for a product throughout the product’s life cycle. Improper disposal of e-waste poses numerous threats to the environment, economy, and health and well-being of citizens. Under the EPR approach, a producer takes the responsibility for financing collection, recycling and end-of-life disposal of e-waste equipment/product streams - batteries, small consumer electronics, accumulators, packaging and other EPR product categories - in order to mitigate the environmental impacts of their products throughout the entire product life cycle. It thereby aims to increase the separate collection of end-of-life products and to enable their more circular treatment.

Implementing EPR can create various environmental, economical and social benefits. Example of EPR benefits include - improved waste collection and treatment, higher rates of waste reuse and recycling, incentivizing greener products, helping to finance waste collection and processing, and generally promoting a sustainable management of waste and circular economy. Governments in low- and middle-income countries are increasingly interested in implementing an EPR system in various forms through a system where they: define the products covered, the producers affected, the obligations imposed on producers - targets and fees, disseminate information on EPR and e-waste to stakeholders and citizens, and have a process to ensure effective monitoring and enforcement of the EPR.

Stakeholders

  • Ministry of Environment or any Ministerial body in charge of environmental, recycling, waste, ICT and/or circular economy related regulations and policies.

  • Inspectorate, Competition and Consumer Protection Authority or any governmental body that ensures the protection and promotion of basic consumer rights as well as safeguarding healthy competition among enterprises.

  • Utilities Regulatory Authority or any governmental body with the mandate to license, monitor and enforce license obligations in the ICT sector.

  • Revenues Authority or any government revenue collection agency in charge with enforcing, assessing, collecting, and accounting for the various taxes imposed in a country.

  • Producers/business operators that manufacture, import, distribute, resell and/or assemble electrical and electronic equipments (e-waste products).

Sustainable Development Goals (SDGs)

  • SDG 11: Sustainable Cities and Communities

  • SDG 12: Responsible Consumption and Production

Building Blocks

Source Documents

Steps

1 - Outreach and EPR Framework

The Ministry of Environment or relevant Ministry, should coordinate with relevant authorities i.e. the Inspectorate, Competition and Consumer Protection Authority, Utilities Regulatory Authority, the Revenues Authority etc., to develop and establish a legal EPR Framework and Implementation Plan that outlines the responsibilities and role of all relevant authorities. The EPR framework should include key clauses on scope of obligated products, stakeholder roles and responsibilities, financing mechanism, targets, penalties, authorization procedure, reporting, monitoring and enforcement mechanisms. To formulate this document, the Ministry can map policies and learnings from other countries, evaluate e-waste quantities and flows within their country, analyze waste management infrastructure and skills, as well as existing policies and legislation at national and sub-national level.

As a next step, the draft Framework can be shared with a core group of diverse stakeholders including other government authorities, civil society actors, and private sector actors that are electrical and electronic equipment producers (importers, distributors, manufacturers and resellers) - to review and comment on the draft document via workshop format sessions. A co-creation session with this group around the registration and EPR fee payment procedure would be very useful to acquire input from producers, and promote a user-friendly EPR designed process.

Once the EPR regulations and processes have been finalized, information on the EPR scheme can be disseminated via - media campaigns facilitated by relevant government authorities, and through local private sector federations/associations.

Workflows

  • Client education for educating and/or informing producers (e.g. an importer, manufacturer, distributor or reseller) on the EPR legal framework, requirements, fee as well as sustainable e-waste management and collection systems they are recommended to implement.

  • Client communication to facilitate information dissemination of the EPR Framework and electrical and electronic product license and registration process via government and business registration and licensing websites, mobile / media channel(s)

    • Country wide campaign to increase awareness amongst local population about how and where to drop off old electrical and electronic equipment and the status of e-waste collection and management in the country.

  • Identification and Registration where target producers register with the relevant Regulatory Authority of the EPR system, apply for operational licensing and register the electricals and electronics they intend to introduce (new or used) into the market. Producers are then allocated a certificate of approval with an EPR registration certificate and operational license number for identification purposes.

  • Content management for the backend EPR Regulatory and Revenue Authorities to populate, track and monitor e-waster producers (electronic manufactures, e-waste importers, e-waste management and recycling companies), and their registered products.

Building Blocks

Messaging

Scheduler

2 - Producer Registration

Producer registration is the process of collecting information of a new business - i.e., a business' name, purpose, tax data, etc – required by the chamber of commerce and/or relevant government authority as part of the business registration process. In this use case, producers (e.g. an importer, manufacturer, distributor or reseller) of electrical and electronic equipment have to register with the relevant Inspectorate, Competition and Consumer Protection Authority, as a business entity planning to operate in the electrical and electronics sector. A certificate of domestic company registration will be provided to the producer following their provision of the required registration information. The business registration certificate is a prerequisite in order for the producer to then apply for the operational license required to put electrical or electronic equipments on the market.

Workflows

  • Data Collection and Reporting for capturing the business registration information of producers wishing to operate in the electronics and electrical sector.

  • Identification and Registration for locating, authenticating and tracking business operators registered in the EPR system.

  • Client Case Management for automating the process in creating, collecting and organizing the registered producers' records in one place. This will allow the convenient access and a comprehensive view of each registered producer in order to initiate and manage compliance. Moreover, support improved and timely registration services, and back office efficiencies.

Building Blocks

Consent

Digital Registries

Identity

Information Mediator

Registration

3 - Licensing

Licensing is the process to acquire authorization from a government agency to operate in a sector that has specific requirements that need to be met. In this use case, licensing is fee-based and is the process for business operators, manufacturers, importers, distributors or assemblers of e-waste products, to apply for operational permission to introduce e-waste products into the local market. The local government's Regulatory Authority makes the decision on whether or not to issue an EPR license. This license is required for all producers to acquire prior to registering the specific type of e-waste product(s) they plan to introduce into the market. Licensing application to include i.e. licensing application fee payment receipt, completed application form, certificate of domestic company registration, environmental impact assessment, audit certificates etc). Certain countries also require site visits of a producers warehouse/factory prior to approving the issuance of a license.

Workflows

  • Data Collection and Reporting for capturing and evaluating licensing application data submitted by producers of e-waste products.

  • Identification to easily be able to identify and track registered business operators applying for a license within the EPR system.

  • Client Case Management to help automate and manage the licensing application and approval process, schedule site visit appointments of e-waste factories/warehouses, and distinguish between new and renewal licensing applications. Moreover, support in vetting/ensuring the applicants meet the eligibility requirements, and have submitted all required documentations.

  • Client Communication to update producers on additional documentations required and/or application status updates/outcome.

  • Financial Services for facilitating one off licensing application fee payment by the producer and allocation of a fee payment receipt.

Building Blocks

Consent

Digital Registries

Identity

Information Mediator

Messaging

Payments

Scheduler

4 - Product Registration

Registration is the process of documenting and maintaining records of registered electrical and electronic products (new or used) being manufactured, distributed, imported and sold on the market. All licensed producers will be required to register the respective type of e-waste goods they wish to introduce to the market - in order to obtain a registration number/code for each type of product. As part of the product registration process: producers submit a completed product registration application form with agreement to comply to the EPR, the product user manual, installation manual, and document indicating product life span. The producer completes this registration process by paying the product registration application fee and receiving a receipt confirming payment. Some producers may be requested to submit a product sample. Based on whether a producer imports their e-waste products, additional data might be requested (i.e. import permit, product country of origin etc). Once all requirements are met, the producer receives a registration number/product code.

Workflows

  • Data Collection and Reporting for capturing the registration data of e-waste product(s) that will be on the market.

  • Identification and Registration for locating and tracking e-waste products being introduced into the market in all phases of their life cycle.

  • Client Case Management for automating the process in creating, collecting and organizing the registered e-waste products' records in place. This will allow the convenient access and a comprehensive view of each type/category of registered e-waste products in order to calculate EPR fees and manage compliance.

  • Financial Services for facilitating one-off product registration application fee payment by the producer and allocation of a fee payment receipt.

Building Blocks

Consent

Digital Registries

Identity

Information Mediator

Payments

Registration

5 - Data Verification and Validation

Data verification and validation should be coordinated with all relevant governement authorities and regulatory bodies. For the EPR system, in certain countries, the registration data collated of the e-waste producer and their products by the respective business registration and licensing authorities, is then generally checked by the Ministry of Environment, and against other government databases (eg. ID, tax, chamber of commerce, etc.) in order to fill in any missing gaps, verify and validate collected information, including authentication of all records. *Data checking approaches also vary: sometimes batch-sharing via CD, sometimes full interoperability.

Workflows

  • Client Case Management for storing and reviewing identification, registration, and licensing records.

  • Data Analysis and Business Intelligence for cross-referencing and verifying records across multiple registry sources, and reconciling gaps / overlaps.

Building Blocks

Consent

Digital Registries

Identity

Information Mediator

Workflow

6 - Payment

For this use case there are three specific payments: (1) producer licensing fee, (2) product registration fee, and (3) EPR fee.

The producer licensing fee and the product registration fee are to be paid as part of each application process/phase, to the respective government agency in charge of allocating EPR licensing and EPR products registration. A payment receipt is to be provided to each producer for each payment made.

The concept of the EPR policy scheme is that an EPR fee is to be paid for each type of electrical and electronic equipments introduced into the market every year. The fee will be used at the end of the product lifecycle to cover the collection, treatment, recycling and awareness raising when it becomes e-waste. The EPR regulatory framework must clearly spell out which entity will collect the EPR fee, how much the fee is, what the methodology is being used to determine the fee, and how payment should be processed. For instance with e-waste products being imported, the EPR fee can be collected at the point/port of entry by Customs Revenue Authority or the Utilities Regulatory Authority. The EPR fee can be collected with the import tax fee etc. To facilitate this, producers could be required to declare cargo (online: e-single window) and make the payment through an online portal.

The fee to be paid could be proportional to the amount of electrical and electronic equipment introduced into the market. Below are examples of methods that can be used to arrive at the fee:

  1. Product EPR fee paid by the producer = Total costs for waste stream divided by/ Mass of product type put on the market.

    1. Market share calculation for a producer:

      • Market share = The weight of products put on the market by an individual producer per product type divided by/ The total weight of products put on the market by all producers for that specific product type

    2. Obligation calculation for a producer:

      • Obligation for a producer = Total reported tonnage by product type multiplied by* Individual producer's market share

    3. Total costs per e-waste product stream:

      • Total costs = Overhead costs per product type multiplied by* % Market share + Operational costs (per tonne) multiplied by* Tonnes collected

  2. Product EPR fee paid by the producer = An EPR cost is calculated and associated for every possible type of e-waste product. Thus, the EPR fee a producer has to pay is the quantity of a product they plan to introduce into the market multiplied by the EPR cost associated with the product type.

Workflows

  • Financial Services for processing EPR fee payments by producers.

  • Client Case Management for identifying, authenticating and monitoring/verifying that the e-waste producers have made the EPR payment and the transaction has been fully processed and received.

Building Blocks

Digital Registries

Messaging

Payments

Workflow

7 - Ongoing Case Management

This step involves ensuring information of e-waste producers are kept up to date - specifically relating to registration and licensing. Also ensuring that there is a process in place to address any complaints, grievances and appeals raised by the producers. This process should be led by the government authority's EPR compliance officers/team.

Workflows

  • Data Collection and Reporting for capturing changes in producer's information (e-waste products, licensing etc).

  • Client Case Management for identifying and recording producer interaction with EPR compliance officers and capturing reported cases on grievances / appeals etc., and for determining decisions/actions to proceed with by reviewing individual producer client case.

Building Blocks

Consent

Digital Registries

Identity

Messaging

Scheduler

Workflow

8 - Ongoing M&E

The government authority leading the EPR implementation should also allocate a team in charge of regulating EPR compliance and enforcing penalties. A monitoring team consistently tracking all e-waste operators active in the market, registered with a license within the EPR system and payments of the EPR fee. A live database should be put in place to categorize and track e-waste products in the market and EPR fee payments from the producers. Late payments can be tracked and an automated system put in place to send out late fee penalties to the producers.

Workflows

  • Financial Services for processing late EPR fee payments by producers.

  • Client Case Management for identifying, authenticating and monitoring/verifying that the e-waste producers have made the EPR fee payment and the transaction has been fully processed and received.

Building Blocks

Digital Registries

Identity

Messaging

Payments

Workflow

Contributors

  • Garam Bel, Circular Economy Coordinator, International Telecommunication Union (ITU)

  • Wesley Brown, GovStack Product Owner, Digital Impact Alliance

  • Taylor Downs, CEO and Founder, Open Function

  • Jaume Dubois, Digital ID Lead, GovStack

  • Longin Dusengeyezu, Database and Applications Lead, Rwanda Institute for Conservation Agriculture (RICA)

  • Theophile Dusengimana, Environment and Climate Change Policy Specialist, Rwanda Ministry of Environment

  • Hani Eskandar, Head of Digital Services, International Telecommunication Union (ITU)

  • Sarah Farooqi, The Exchange Product Owner, Digital Impact Alliance

  • Sainabou Jallow, Business Analyst, Digital Impact Alliance

  • Concord Kananura, GovStack Africa Regional Coordinator, International Telecommunication Union (ITU)

  • Dismas Karuranga, Pollution Control Specialist, Rwanda Ministry of Environment

  • Nico Lück, GovStack Advisor, GIZ

  • Margus Mägi, GovStack Project Lead for Estonia, Governement of Estonia

  • Yolanda Martínez, Overall Lead for GovStack, International Telecommunication Union (ITU)

  • Antoinette Mbabazi, Head of Registration& Licensing Department, Rwanda Institute for Conservation Agriculture (RICA)

  • Olivier Mbera, Country Manager, Enviroserve Rwanda

  • Robert Mugisha, Director of Registration& Licensing Unit, Rwanda Institute for Conservation Agriculture (RICA)

  • Eric Murera, Environment Expert, Private Sector Federation (PSF) Rwanda

  • Dr. P. S. Ramkumar, GovStack, International Telecommunication Union (ITU)

  • Ayush Shukla, Technical Officer, International Telecommunication Union (ITU)

  • Patrick Umuhoza, Multilateral Cooperation Officer, Rwanda Environment Management Authority

  • Olivier Urukundo, Engineering Risk Analysis Specialist, Rwanda Institute for Conservation Agriculture (RICA)

  • Eng. Gaston Uwayo, TMEA ICT Technical Assistant, Rwanda Standards Board

  • Damascene Uwizeyemungu, IT Officer, Rwanda Utilities Regulatory Agency

  • Meelis Zujev, Project Manager, Govstack Sandbox, Gofore

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