Control & Compliance

Free Riders

Both SWICO and SENS have to contend with the free riders problem, albeit, the percentage of such producers is minor and is limited to only small companies. In some sectors, such as photocopiers and cell phones, there is 100% participation. The legislative backing of the ORDEE has ensured that the free riders problem is contained. Peer group pressure is one of the most important means of reducing free-riding and both the systems depend on participants, mainly producers, retailers and recyclers, to report non-compliance. Large retail chains, such as Migros, insist that vendors already be a part of the recycling system before carrying their products. Thus, there is a multi-point control mechanism built in to prevent free riding.

The high rate of participation is also due to the low cost of participation in the system for producers. The only requirement is that they report their sales figures and credit the associated ARF to the recycling funds.

At the start however, when the SWICO system started, it did not have such high rates of producer participation. For example, at the beginning, HP decided not to take part in the SWICO system. However, in the e-waste collected, there were substantial amounts of discarded HP products. Thus SWICO approached HP and asked them to pay for the recycling costs incurred on their products. HP joined the system in 1996, realising that the cost of collection and recycling, as well as the administrative overhead, would be much lower through the SWICO recycling guarantee.

Uncooperative Retailers

Neither SWICO nor SENS receives many complaints about retailers not taking back discarded appliances for free. For a retailer, the take back is a way of providing additional service and is an opportunity to build customer relationships. At the onset, small retailers were concerned that their stores would be flooded by returned products for which they did not have the infrastructure. However, the retailers concerns were misplaced. Current statistics from SWICO's 2003 report show that collection of the e-waste by the trade was almost the same as that of collection points, being 40% and 39% of the waste collection respectively. The balance 21% was collected directly by manufacturers/ importers and logistics companies.

The SWICO and SENS system also have the support of the ORDEE which makes it obligatory for retailers to take back products. Thus, they are more than glad to participate in a system that organises the forward logistics and financing.

Consumer Inaction

The structure of both the SWICO and SENS systems ensures that it is convenient for a consumer to bring back unused appliances to designated points. By making this return free of cost at the point of disposal, the consumer has no incentive to dispose the appliance illegally or in the regular municipal waste. The ORDEE stipulates that it is the responsibility of the consumer to bring products to designated places so that they may be disposed properly. A study in 2001 by SAEFL (2004a) found almost no e-waste in municipal solid waste. Of the few pieces of e-waste found in household waste, most were cables and wires. Neither is e-waste seen being disposed in the open or in forests. A reason for this is the high level of awareness and concern for the environment in the population as well as a habit of segregating various kinds of waste before disposal. However, there is scope for improvement in the awareness levels; because of the estimated 100,000 tonnes of e-waste that is generated annually in Switzerland, only approximately 68,000 was collected in 2003, indicating that consumers tend to store unused appliances.

Controlling material and financial flows

The material flow is controlled at every stage - the manufacturer submits a copy of the products sold, and accordingly the ARF collected, the retailer consolidates the sales of the EEE and the ARF collected there from. At the post consumption stage, the collection sites (both at the retailers as well as independent), quantity of e-waste transported, as well as quantity and quality of the recycling, including the emission levels and precautionary measures, are all inspected by external auditors.

Independent control and monitoring is a necessary prerequisite for an EPR based system to function smoothly. The PROs as well as the government have various means of ensuring standards are met and the system is transparent to all.

Quality & Quantity

The quantity of e-waste coming into the system is controlled by corresponding weight of pallets picked up by transporters from retailers and collection points to those received and processed by recyclers. This not only acts as a control on both transporters as well as recyclers but also helps the PROs gather data at multiple points to be able to improve the logistics chain. The retailers and collection points are also controlled by external controllers to ensure security of e-waste during storage, especially for computers for data protection, and to prevent pilferage. This also acts as a check on the separation of products between the SENS and the SWICO systems, which in turn affects their payments to the recyclers.

Both SWICO and SENS employ external auditors to perform technical controls on recyclers. The third party auditors ensure greater transparency regarding the quality of recycling, which is especially important for companies implementing ISO 14000 norms. The technical controls ensure that the recycler has no more than 20% of the incoming e-waste unprocessed at the end of the year. The technical audits are also important to evaluate recyclers at the time of renewing their contracts.

Targets & Penalties

The ORDEE, unlike several similar directives in other countries such as Sweden and Norway, does not stipulate any specific recycling or recovery targets. The SAEFL did not want to impose a recycling target at any price and therefore preferred to let the industry decide the quantity that was reasonably feasible by balancing economic and environmental efficiency. The current performance of the system, which in 2003 achieved a collection rate of over 9kg/ capita, shows that the system has been more than successful, when compared to the target of 4 kg/capita set in the EU's WEEE directive.