This guidance should be used by any organisation that remanufactures or recycles WEEE.
It should be read with the Guidelines and recommendations for WEEE reuse and recycling operators.
For the purposes of this guidance, ‘recycling’ refers to materials recovery (for example, metals, plastics and glass) for reuse in new products.
Checklists on recycling electrical and electronic services and purchasing recycling services are available for you to print and use.
Priorities for organisations remanufacturing or recycling WEEE
WEEE destined for recycling needs to be managed under controlled processes because the physical dismantling and recycling of the WEEE exposes workers and the environment to the greatest risks.
Organisations remanufacturing or recycling WEEE must:
- protect the health and safety of workers undertaking any disassembly
- control the release of hazardous substances into the environment and capture any hazards.
They should also:
- undertake the appropriate level of remanufacturing to gain the greatest value for the materials
- send the disassembled components and materials to appropriate organisations for the next stage of treatment.
Barriers to recycling WEEE in New Zealand
Recycling of WEEE is currently limited in New Zealand. A lot of activities under the banner of recycling actually involve remanufacturing WEEE into its constituent parts, which are then sent for further processing and materials recovery in New Zealand or overseas.
All remanufacturing operations in New Zealand are manual, and therefore labour intensive. This means disassembly activities are economically marginal and are affected by the costs of labour, landfilling and the price available for dismantled materials.
Whiteware and IT equipment are the most common types of equipment remanufactured or recycled because of the value of the components inside the equipment. However, even for these goods, it can be uneconomic for New Zealand companies to disassemble.
There is increasing competition from overseas processors that take whole equipment and use mechanical disassembly and processing. Many of these companies have expanded from the precious metal sector, and there is growth in South East Asia (Singapore, Korea, Malaysia and the Philippines), India and the USA.
Options for remanufactured and recycled WEEE
As discussed in E-waste in New Zealand: Taking Responsibility for End-of-Life Computers and TVs [CANZ website], the five main options for disassembled parts in New Zealand are:
- component recovery and sale
- materials recovery and sale
- exporting WEEE for 1 and 2 above
- storage until there is a viable option
- landfill.
All these options are practised in New Zealand. Component recovery and sale occurs for some of the more valuable equipment such as IT equipment.
Some organisations are storing WEEE that currently doesn’t have a viable treatment option, such as cathode ray tubes (CRTs) or batteries, although a lot of WEEE is sent to landfill.
Table 8 shows the major components of different categories of WEEE and describes some of the current disposal routes.
Final disposal to landfill in New Zealand
The New Zealand Waste List (L-Code) provides guidance on wastes generated by various industry sectors and municipal wastes. The L-Code contains wastes including those regarded as hazardous. Any waste on the list marked with an asterisk (*) is regarded as a hazardous waste according to the Draft Definition of Hazardous Waste. A number of WEEE are marked as hazardous waste on the New Zealand waste list, for example, discarded electrical and electronic equipment containing hazardous components.
The Ministry for the Environment has published two guidance documents, Module 1: Hazardous Waste Guidelines - Identification and record-keeping and Module 2 – Hazardous Waste Guidelines: Landfill Waste Acceptance Criteria and Landfill Classification.
Under these guidelines, landfills with a higher standard of environmental protection (Class A landfills) will be able to accept wastes subject to less stringent criteria than those applicable to lower standard (or Class B) landfills. This will result in hazardous wastes only being able to be accepted after they have been treated or stabilised to minimise hazards and then disposed of at landfills that offer an appropriately high standard of environmental protection.
Hazardous substances in WEEE
Many items in WEEE contain hazardous substances that can be released during:
- destructive disassembly and recycling practices such as heating, crushing or shredding
- landfilling
- incineration.
Appropriate measures must be in place to identify and mitigate the hazards.
During normal use of electrical and electronic equipment there is no risk to human health or the environment because “nearly all the substances of concern are in a solid, non-dispersible form” (OECD, 2003b). However, they do pose a concern once they become WEEE and are either treated or disposed of.
The most common hazardous substances in WEEE are shown in table 9.
| Antimony Arsenic Asbestos Barium oxide Beryllium Cadmium Chlorofluorocarbons and hydro chlorofluorocarbons |
Chlorine or brominated flame retardants Cobalt Copper Lead Lithium Mercury Nickel |
Poly-chlorinated biphenyls Selenium Silver Tin Zinc |
Source: Technical Guidance for the Environmentally Sound Management of Specific Waste Streams: Used and Scrap Personal Computers [OECD wesbite]; Environmentally Sound Management Used Mobile Telephones (http://ipmi.org/, PDF, 257 KB] [International Precious Metals Institute, 2003].
These substances are mainly contained in circuit boards, cathode ray tubes (CRTs), liquid crystal displays (LCDs), lamps, casings, wiring, batteries, refrigerant systems, and solder.
Some of the hazards only relate to particular types of historical WEEE, because technological advances have reduced the use of that type of equipment. As a result, they will not be a significant problem in the future, although the replacement technology could contain other hazards that require different treatment. The best example of this is the switch from CRT monitors to LCD screens.
The European Union restriction on the use of certain hazardous substances in new electrical and electronic equipment (known as the RoHS directive) has banned the use of six hazardous substances from manufacturing processes:
- cadmium
- mercury
- hexavalent chromium
- polybrominated biphenyls
- polybrominated diphenyl ethers
- lead.
Many manufacturers and component suppliers, even outside of the European Union, now require RoHS compliance for all products. However, this is not necessarily the case for items entering the New Zealand market.
The onus is on the original equipment manufacturer and/or the recycler to identify which hazardous materials are present, because it varies greatly between the product, brand, age and model. It is the original equipment manufacturer’s role to keep recyclers informed of which hazardous materials are in their products.
Guidelines and recommendations for remanufacturers and recyclers
This information should be read with the general guidelines and recommendations in the Guidelines and recommendations for WEEE reuse and recycling operators section.
All remanufacturers and recyclers should be committed to:
- minimising the health and safety risks associated with remanufacturing, treating and recycling WEEE
- minimising the risk of releasing hazardous substances into the environment
- meeting international standards.
Minimum treatment criteria for major hazards in WEEE
The European Union (EU) WEEE directive focuses on a number of major hazards and describes minimum treatment criteria for these. It is recommended that the same treatment criteria be adopted by remanufacturers and recyclers in New Zealand because:
- the EU criteria identify the major hazards to be removed
- the EU, as the first region to adopt WEEE legislation, has extensive experience, resources and several years of research and development into treating WEEE.
In the UK, the Department for Environment, Food and Rural Affairs has published guidelines (PDF, 123 KB] [Defra UK website] on the best recovery and recycling techniques for treating WEEE (Defra, 2006). These guidelines set out how the UK Government interprets the EU requirements. Table 10 highlights the key EU requirements and identifies how appropriate and relevant they may be to New Zealand.
| Item to be removed | Where the item is found | The UK requirements | Discussion for New Zealand application/relevance | |
|---|---|---|---|---|
| 1 | Fluids (non-refrigerant and refrigerant) | Heating and cooling devices (fridges, freezers and oil-filled radiators). Motor vehicles. |
Removal of all fluids before crushing or shredding. All recovered oils and fluids separately contained and disposed of according to legislation covering hazardous waste and ozone-depleting substances. |
This would affect the scrap metal sector, although the presumption is that fluids are already drained. Lubricating oil from refrigerators and air conditioning units initially still contains refrigerant gases so should be removed and collected even after degassing. |
| 2 | Capacitors containing polychlorinated biphenyls | Historically used in capacitors and transformers, but they have been phased out and are unlikely to be found in appliances less than 20 years old. | Remove and dispose of separately. The Defra guidance (www.defra.gov.uk, PDF, 123 KB] gives more detail. |
This relates to historical wastes only. |
| 3 | Mercury-containing components | Gas discharge lamps, medical equipment, data transmission, flat-panel displays, mobile phones and telecommunications, batteries, thermostats, position sensors, relays and switches. | Good practice is to remove mercury-containing components before shredding. Printed circuit boards (see item 5 of this table). Batteries (see item 4 of this table). Gas discharge lamps (see item 11 of this table). |
If batteries, lamps and circuit boards are already separated this is not a problem. They will be dealt with by specialist facilities experienced in recovering mercury. It may be appropriate, in some circumstances, to keep the mercury-containing components integrated for safer transportation. If a closed processing system exists, some of these items can be shredded without removing the mercury-containing components. The mercury has to be contained in the closed system and handled as hazardous waste. |
| 4 | Batteries | A range of applications, separate battery packs and small back-up batteries on mother boards. |
Gives advice on when to remove, but where practical should be removed intact and stored in appropriately labelled containers. Fire risk should be mitigated. |
Guidelines for treating loose batteries (those not integrated into any electronic hardware) may be more appropriately handled using group standards under the Hazardous Substances and New Organisms Act 1996. The requirement to remove back-up batteries from circuit boards before shredding may not be applicable in New Zealand if all printed circuit board processing takes place overseas, but current practice suggests most batteries are not removed from printed circuit boards before shredding. |
| 5 | Printed circuit boards where the surface of the circuit board is greater than 10 cm2 | Found in any piece of EEE. | Remove circuit boards from all WEEE and send for specialist recovery, even if the final destination is landfill. |
This would cover a range of appliances. If a closed processing system exists, some of the items can be shredded before removing the printed circuit boards. The printed circuit boards have to be contained in the closed system. |
| 6 | Toner cartridges | Printers, fax machines and photocopiers. |
Removed whole and intact. Stored in suitable containers for recycling/reuse. |
The Australasian Cartridge Remanufacturers Association has details of cartridge remanufacturers and recyclers in New Zealand working to a code of practice. Some original equipment manufacturers also remanufacture or recycle printer cartridges. Details of the standards they follow should be requested from the original equipment manufacturer. |
| 7 | Plastics containing brominated flame retardants (BFRs) |
A number of different flame retardants have been used in electrical and electronic equipment (see Defra guidance (www.defra.gov.uk, PDF, 123 KB] for more detail). Treatment facilities must distinguish between plastic containing BFRs and those that don’t. If they cannot be distinguished, the assumption should be that they contain BFRs. |
Any BFR plastics should not be recycled within the normal plastics recycling infrastructure due to contamination. After separation, the BFR containing plastics should be sent to the appropriate recycling end-use specific to plastics containing BFRs. |
Some work has been done to commercialise the removal of BFR from plastic (http://www.wrap.org.uk), but this is not readily available. |
| 8 | Asbestos waste and components that contain asbestos | Items over 20 years old may contain asbestos and should be examined (eg, toasters and irons). |
If identified, asbestos should be sent for appropriate disposal. Specific measures are needed to protect workers. |
The main impact in New Zealand would be on reuse programmes from householders, where old toasters, irons and coffee pots may contain asbestos. |
| 9 | Cathode ray tubes (CRTs) | Computer monitors or TVs. |
Removal of CRTs from separately collected WEEE.
|
Few commercial operators undertake this within New Zealand. |
| 10 | Chlorofluorocarbons, hydrochlorofluorocarbons, hydrofluorocarbons and flammable hydrocarbons |
Appliance insulation. Refrigerants and cooling equipment (fridges, freezers, air conditioners). |
This covers foam as well as the removal of gases. Follow the Australia/New Zealand Refrigerant Handling Code of Practice. |
Ozone-depleting substances are already covered by regulation in New Zealand. New Zealand’s obligations under the Montreal Protocol are implemented through the Ozone Layer Protection Act 1996 and the Ozone Layer Protection Regulations 1996. However, chlorofluorocarbons in foam are not removed in New Zealand. |
| 11 |
Gas discharge lamps (fluorescent lamps) |
Appliances such as refrigerators and computer monitors, laptops, handhelds and printer displays with fluorescent lamp backlights. |
Vacuum-controlled shredding/crushing followed by separation into glass, metal and powder. |
Individual fluorescent lamps can already be collected and crushed in New Zealand before the material is exported overseas for further processing and recycling. |
| 12 | Liquid crystal displays (LCDs) | Mobile phones, computer monitors. |
Removal of any gas discharge lamps that provide the backlighting for the LCD if their surface area is greater than 110 cm2. Where the process exists, they can be recycled without removal. |
There is currently no disposal route for LCDs in New Zealand except export overseas for processing. It may be appropriate to keep the item intact for safer transportation when exporting overseas. |
| 13 | External electric cables | Found in all items of WEEE. |
Removal either before or after manual or mechanical disassembly of WEEE. |
Several recyclers in New Zealand accept electric cables and wiring for recycling and separate the copper from the PVC. |
| 14 | Components containing refractory ceramic fibres (RCFs) | Furnace/heat kiln linings. RCFs may be used in both domestic and building heating appliances, although the insulation materials used in domestic electrical appliances are more likely to contain mineral wools. |
Appliances that may contain RCFs should be examined. | This covers only a small number of items and would only have a limited impact. |
| 15 | Components containing radioactive substances (note exemptions) | Certain medical test equipment and smoke detectors (although ionisation chamber smoke detectors used in domestic smoke detectors should be below the limits). | Should be removed whole, except those that are exempt under the UK requirements. | Radioactive substances are already included in New Zealand legislation and the Auckland Regional Council / Scrap Metal Recycling Organisation report also gives guidance in this area. Radiation Protection Regulations 1982. |
| 16 | Electrolyte capacitors containing substances of concern, over 25 mm or proportionally similar volume | Typically smoothing capacitors in power supplies that use a transformer (eg, stereo equipment). | The advice from Defra is that modern electrolyte capacitors are unlikely to contain hazardous substances and nearly all are mounted onto circuit boards so would be removed with the circuit board before landfill. (See printed circuit boards – item 5 of this table.) |
Source: Based on Defra, 2006. See the full document for more detail.
Operating principals
Remanufacturers should:
- only disassemble equipment to the level of their technical and operational competence
- operate in a way that maximises the recycling of the constituent parts of the WEEE.
All separately disassembled equipment must meet the treatment criteria, as summarised in the Summary of treatment criteria table.
Controlling hazards
Remanufactures and recyclers must control the release of hazardous substances from the WEEE they are handling. They must have an established system and plan to identify and manage hazardous substances removed during remanufacturing.
The remanufacturer must have scanning and testing equipment and/or procedures to work out if there is hazardous substances in the equipment and if so, the type/s of hazardous substance.
There must be adequate control of indoor and outdoor hazardous air emissions (identified through the risk assessment process).
All hazardous wastes must be dealt with according to current legislation and good practice. This includes Basel consents, hazardous waste movements, greenhouse gas regulations, and hazardous substances and new organisms group standards [ERMANZ website].
Hazardous substances must only be handled by suitably skilled and qualified staff.
Where ‘destructive’ remanufacturing is taking place, operators must make sure their health and safety risk assessment includes risks of worker exposure and environmental releases of lead and other hazardous substances. Destructive remanufacturing includes the application of heat or the use of crushing and grinding equipment.
Appropriate facilities, protective equipment (such as safety goggles, overalls, rubber-soled shoes, face masks, cut-resistant gloves and hearing protection), and staff training should be provided.
Good practice standards of care – down the chain
When sending disassembled (or intact) WEEE for further treatment, the remanufacturer must make sure:
- it meets the guidelines and recommendations set out here and in the Guidelines and recommendations for WEEE reuse and recycling operators section
- any specific hazardous substances identified in table 9 are dealt with appropriately
- overseas operators have appropriate management, technical and operational systems to minimise the release of hazardous materials, and that any specific hazards are treated to at least the minimum accepted treatment criteria
- Basel permit is in place, where appropriate.
Working with overseas recyclers
WEEE exported from New Zealand should only be sent to organisations where there are assurances they are operating safely. Overseas operators should have an independently accredited environmental management system. This could be any of the schemes identified in Table 12.
Even if an operator has an accreditation, it is important to request:
- a copy of the certification – check it is still valid and it covers the recycling activities. It could be that only some activities or branches are certified under the environmental management system and they might not cover the recycling activities
- a copy of the last two audit reports (for example, ISO 14001 is audited every six months, so by checking the latest audit reports you will be able to assess if the company has had any non-compliance with their environmental management system and what corrective action they have undertaken).
Any exports to overseas operators must be in line with the Basel requirements for trans-boundary movements of hazardous wastes. See the Exporting hazardous WEEE section for more information.
Further sources of information on recycling WEEE
| Source | Comments |
|---|---|
| Technical Guidelines for the Environmentally Sound Management of Waste Lead-acid Batteries. Basel Convention. 2003. | These guidelines provide guidance to countries/organisations wishing to improve their management of used lead-acid battery wastes. |
| Tools for Environmentally Sound Management for an ISO compliant Environmental Management System that includes OECD Core Performance Elements for the World’s Recycling Industries (www.basel.int, PDF, 1.58 MB] . Bureau of International Recycling. 2006. | These tools help recyclers demonstrate their environmentally sound management. They are particularly useful for companies that import materials classified as wastes from countries or regions with strong protection laws for human health and the environment. |
| Oregon Electronics Recycling Program Environmental Management Practices, State of Oregon, Department of Environmental Quality. June 2008. | The State of Oregon in the United States of America administers an e-waste recycling programme, Oregon E-Cycles, which provides responsible recycling of computers, monitors and TVs. The State Contractor Program and approved manufacturer recycling programs must ensure that their contracted collectors, transporters and recyclers meet the environmental management practices. |
| E-waste Volume I: Inventory Assessment Manual (www.unep.or.jp, PDF, 1.72 MB] and E-waste Volume II: E-waste Management Manual (www.unep.or.jp, PDF, 2.19 MB] . United Nations Environment Programme 2007. | The International Environmental Technology Centre has produced two manuals to help member countries and their cities develop inventories and WEEE/e-waste management systems. |
| Environmentally Sound Management and Performance Standards for Direct Processors (www.ecy.wa.gov, PDF, 156 KB] . Washington State Department of Ecology. November 2007. | In 2007, the Washington State Department of Ecology in the United States of America adopted the rule “Electronic Products Recycling Program – WAC 173-900”. Amongst other requirements, the rule includes minimum performance standards for direct processors. This document identifies the performance standards a direct processor must conform with. |
| WEEE Forum’s Frequently asked questions. WEEE Forum. September 2008. | The WEEE Forum is a not-for-profit association which provides a platform to foster ideas and share best practices on the proper management of electrical and electronic waste. |
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Recycling WEEE
March 2021
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