Annex H. Recycling of electronic home appliances in Japan1
1. Description of EPR set-up
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Legal context
The Act for Recycling of Specified Kinds of Home Appliances was enacted in June 1998 and enforced in April 2001. It aims to achieve a reduction in the volume of general waste and sufficient utilization of recycled resources. The Act covers four categories of home appliances: air conditioners; TV sets; electric refrigerators and freezers; and electric washing machines and clothes dryers. Personal computers and small electronic appliances are covered by other legislations.
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Allocation of responsibilities (distribution of roles, financial flows)
Consumers that dispose of the waste of home appliances are responsible for paying both the collection/transportation fee and the recycling fee as well as for the proper returning of the waste to retailers or to put into municipal collection and treatment route. Business disposer/emitter is out of the scope of this law. Those emitted from business facilities are regulated as industrial wastes. Collection/transportation fees are set by retailers depending on the transportation distance and the size and type of waste products, but many large retailers uniformly charge JPY 540 (including consumers’ tax) per unit. Recycling fees are set by manufacturers and are subject to regular reviews by each manufacturer. Retailers are providing a service for (based on a business custom to collect old appliances with a fee (JPY 500 with consumer tax mentioned above: USD 5) when new ones are delivered) collecting the home appliance that they have sold, or to take back the old appliances from customers who buy a new product. Retailers are also responsible of transferring these end-of-life products to designated collection points set up collectively by the responsible manufacturers, or they may contract out these operations to operators certified by the competent authority. Manufacturers and importers have the obligation to set up designated collection points and collect and recycle the home appliance that they produced or imported from these designated collection points. Small and medium-sized manufacturers (defined in the Act according to the category of products) may contract out this responsibility to designated bodies. Municipalities are responsible for managing waste home appliances or WEEE outside the scope of the Act. If they collect waste covered by the Act, they may transfer it to manufacturers or decide to recycle them themselves. The national government (Ministry of Environment (MOE) and Ministry of Economy, Tradeand Industry [METI]) are responsible for supporting activities such as promoting research and development, providing information, developing related facilities, providing technical assistance, conducting and implementing environmental education and information dissemination activities. The government also publish data on annual recycling performance.
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Governance system and sanctions
Retailers and manufacturers who neglect their obligations for collection and recycling as stipulated in this recycling Act, provide false information, or impose unlawful charges are subject to corrective recommendations, corrective orders, or penalties. Monetary penalties range from a fine of JPY 100 000 to JPY 500 000. Individuals who commit illegal dumping are subject up to five years imprisonment or to a fine up to JPY 10 million (or JPY 300 million for corporations) under the Waste Management and Public Cleansing Act.
The Act stipulates that the government must assess the progress of implementation five years after entry into force. For this purpose, a joint advisory council was set up between the MOE and the METI to evaluate processes in, review directions for, and identify issues related to policy implementation, as well as giving advice to the government. Members of the joint advisory council include experts, researchers, representatives of manufacturers associations, consumer groups, local governments, retailers and recyclers. A first evaluation was carried out in 2006-07 that resulted in the publication of a report in 2008. A second review was done in 2013. As a result of this review, the collection target was set at 56% and targets for recycling rates of appliances had also increased.
2. Environmental effectiveness
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Collection and recycling rates
Recycling targets under the Act refer to the percentage recovered from the WEEE for recycling of the total weight of the components and materials in the WEEE. They exclude thermal recovery. As shown in Table H.1, recycling targets were revised in 2009 except for CRT TVs because the resource value of CRT glass has been declining significantly. Also, in 2015, recycling targets are revised again to promote further recycling of collected items.
Over a period of 13 years since the enforcement of the Act, the number of units received by the designated collection sites has been on the rise, and so has the number of units processed for recycling. Overall numbers of recycled units are 174 million units of home appliances between 2001-13. The recycling rate for each category of home appliances has remained high, although it has varied slightly depending on the category (see Figure H.1). In 2013, the recycling rate was higher than the recycling target as stipulated by the Act for each of all the designated categories of home appliances. More precisely, it stood at 91% for air conditioners, 79% for CRT TV, 89% for LCD and plasma TVs, 80% for refrigerators and freezers, and 88% for washing machines and clothes dryers.
Source: Association for Electric Home Appliances (AEHA), Annual report on home appliance recycling for financial year 2012 [in Japanese].
According to a study by the Global Environmental Strategies (IGES), the Act has led to a total recycling volume of 38.4 million m3 of home appliances over a period of 11 years from 2001 to 2011. It has also estimated that the Act may have resulted in avoiding more than 50 % potential GHG emissions from using virgin materials.
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Design-for-Environment (DfE)
The Association for Electric Home Appliances’ (AEHA) Product Assessment Expert Committee develops guidelines and reports that help manufacturers to work on DfE. To this end, the committee exchanges views with officials at recycling plants to identify specific improvements they want to see in product design. It also conducts a questionnaire survey on waste management procedures at these plants. In 2012, the committee issued the third edition of the “Guidelines on the labelling and recycle symbols on plastic parts of home appliances” to promote product designs that facilitate recycling. Focus is placed on the following aspects: fewer types of plastic materials; fewer parts; product structure designed to facilitate disassembly; and labelling of parts with the type of material, the indication of the positions of screws. In addition, to improve communications between manufacturers and recyclers, some manufacturers second their employees to recyclers as researchers or trainees. Training engineers at recycling facilities would improve communications for design for environment between manufacturers and recyclers. Also, recyclers submit written requests to the manufacturers for a better design in the easy-to-recycle process.
3. Economic efficiency (including competition aspects)
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Cost efficiency
There is a lack of transparency in the process of setting recycling fees by manufacturers. However, estimation by the joint advisory council indicates that total costs of recycling have decreased, most likely as a result of increased efficiency with technological innovations. Table H.2 shows the results from the cost and revenues estimation. Explanation on Group A and B (two grouping of manufacturers responsible for recycling) is provided in the following section c) on trade and competition.
A 2005 analysis suggested that the enforcement of the Act had resulted in a total net benefit of JPY 54 billion. This is due to two parallel tendencies. First, a reduction of JPY 38.1 billion in costs, which comes from a reduction of JPY 44.5 billion in costs borne by the local governments and an increase of JPY 6.3 billion in costs borne by the private sector. Second, an increase of JPY 15.8 billion in benefits which comes from a JPY 1.6 billion reduction for the local governments and an increase of JPY 17.5 billion in benefits or the private sector.
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Leakages and free riders
As a result of the consultations undertaken in 2006-07 and following a request from stakeholders, the joint council decided to strengthen measures against illegal dumping and improper exports. Indeed, hidden flows outside the recycling chain under the Act are an important concern. It is estimated that almost half of the waste home appliances covered by the Act is not subject to the collection mechanisms stipulated by the Act and about 30% is traded as second-hand goods or metal scarp. In addition, there are concerns that the current system of payment at the time of disposal may encourage illegal dumping by customers. The government is taking measures in order to prevent illegal dumping and export of WEEE as second-hand goods, which may be handled in an environmentally improper manner when exported to developing countries. Such measures include developing clearer criteria for second-hand use in relation to exports, closer partnership with customs authorities, promoting co-operation with trading partners and supporting implementation of the Basel Convention.
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Trade and competition
In order to ensure competition in the home appliance recycling sector, manufacturers are organised in two groups under the Act. Both groups are almost equal in terms of the number of units manufactured and the number of units processed for recycling. Both groups have established their own joint recycling management companies. Designated collection sites accept products from both groups in order to ensure efficiency. The result has been a decline in recycling costs. The MOE-METI joint advisory council are reflecting on how to further reduce fees and ensure they are set in a fair and competitive manner.
4. Key issues and possible reforms
A second review process was completed in 2014 and the joint advisory meeting delivered certain recommendations based on requests made by stakeholders, as follows: setting 56% collection target and increased recycling target rates; greater transparency on the process of setting fees and reduction of the financial burden on consumers; a clearer distinction between the 3R activities; a review of the current license qualifications for collection, transport and recycling plants in order to ensure greater participation, and stricter regulations and measures against the flow of WEEE towards other countries. However, although the possibility of shifting payment at the time of disposal towards a system based on payment at the point of purchase was discussed, the timing of the recycling fee payment was not changed.
Note
← 1. Full source available at: Hotta, Y., A. Santo, and T. Tasaki (2014), “EPR-based Electronic Home Appliance Recycling System under Home Appliance Recycling Act of Japan”, Case study prepared for the OECD, www.oecd.org/env/waste/gfenv-extendedproducerresponsibility-june2014.htm.