Managing Waste Electrical & Electronic Equipment 30 April 2010

Response to the Consultation Document:
Safe and Sustainable: A New Producer Responsibility Scheme for Waste Electrical and Electronic Equipment (WEE)

Submitted to the Environmental Protection Department


Living Lamma welcomes the government’s efforts to protect the environment through the proper treatment of waste electrical and electronic equipment.

There is a growing problem with this and other types of waste on Lamma Island, much of it placed on private land.

If the owner of the land does not wish to clear up the waste, then little can be done. Though there have been many complaints about such waste from the wider community, under current legislation, such dumping does not constitute a nuisance. It is viewed as the ‘storage of personal property on private land’, rather than dumping.

The potential damage to the environment and to human health from waste electronic and electrical items is well documented, and clearly outlined in the first section of the consultation paper. We, therefore, urge government to consider measures to enforce the removal of such equipment from government and private land, particularly from rural areas.

Producer Responsibility

We agree that measures to encourage producer responsibility would be appropriate for the correct handling of waste electrical and electronic equipment in Hong Kong. We also believe that the right strategy is to incorporate the cost of recovery into the price of the item at the outset and to require the producer to take back old items.

It would not be appropriate to charge for disposal at the end of the product’s life. We believe that this would result in more dumping, particularly in remote areas.

Similarly, there should be no exemptions in the take back schemes to exclude areas in the rural New Territories or the outlying islands. It is precisely the rural areas that most need this type of scheme and it is these areas that are most easily damaged by inappropriate disposal. Exemptions will just lead to the dumping of this waste in some of Hong Kong’s most ecologically sensitive areas.

Experience from Other Countries

We believe that currently much of the waste electrical and electronic equipment is ‘stored’ (dumped) on private land because of the difficulties involved in removing such items. Many are too heavy or bulky to be removed easily.

To prevent the dumping of such items, local authorities in other countries provide free pick up of large electrical items on designated days. This represents a cost to the community, as this service must be paid for through taxes. However, it also ensures that these items are disposed of correctly, preventing the even greater environmental cost to the community should these items be dumped.

Consequences of Government Policy

In 2006, the government introduced charging for the disposal of construction waste. Since then, there has been a notable increase in the dumping activities of private landowners, often destroying areas of natural beauty and ecological value. Though much of this waste is construction rubble, it is not sorted and includes a wide variety of inert and non-inert materials, effectively creating private, unlicensed landfills in residential areas.

Such activity has put Lamma’s environment on a downward spiral, whereby there is dumping of all kinds of waste, including electrical and electronic equipment (see attached photographs). Often such waste is “stored” on the harbour front for weeks, before the owner arranges transportation off the island. Other times, these items are considered abandoned and eventually removed by government.

Some Suggestions

Living Lamma would like to see measures taken to ensure the proper disposal of waste electrical and electronic items as part of an integrated programme of community waste management, which would aim at reversing the environmental degradation caused by the ‘storage’ or ‘depositing’ (or dumping) of waste on private land.

To do this, the EPD should organise community outreach, both to educate people on the hazards caused by waste and the benefits of proper disposal and to understand the needs of particular communities in dealing with their waste. This could make a huge difference in combating dumping, particularly if government were to provide the right assistance in cleaning up areas of private land.

In other parts of the world, local authorities provide facilities where certain types of waste can be recycled within communities, through the provision of tip shops or waste-to-art programmes. In Hong Kong, beyond the general rubbish and limited recycle bins, few facilities are provided to the community. Government can only issue a letter asking a private landowner to clean up his land, but this is rarely enforceable. Often the owner may have died or moved away, or not be able to move the waste. We know of two cases on Lamma where landowners have been issued with letters to remove old, rusty diggers from their land, but given no indication how they might do this.

There should also be an examination of ways in which such waste could be cut at source. For example, last year the European Commission asked for and received commitment from major mobile phone providers to harmonise phone chargers in order to cut waste. Equally, waste could be significantly reduced if chargers were sold separately. Often electrical and electronic items come with a number of unwanted accessories. Could these be left behind at retail outlets to be reused or disposed of properly by the producers?

Finally, we would urge government where possible to pilot any scheme so as to avoid any unintended consequences, such as the increased incidences of dumping that have resulted from the introduction of charging for the disposal of construction waste.

Photographic Evidence from Lamma Island

  1. Electrical and Electronic Waste

2. The Unintended Consequences of Government Policy – Dumping or the “Storage of Construction and Demolition Waste”?

  1. The government has issued a letter to remove this. It is beyond local resources and capability to do so. How can the government help?

Living Lamma

Author: Jo Wilson

April 2010