"Recycling must be the last stage for a product"

In June 2020, the government appointed a special investigator to review the possibilities of introducing a deposit system for small electronics. The investigation was presented to the government in the spring and gave clear messages that a deposit system would be both difficult to implement and unlikely to have the desired effect, something that IT&Telekomföretagen also pressed for and which we develop in our response toreply to public consultation SOU 2021:26 Use what works).

Frida Faxborn, an expert on industrial policy at IT&Telecom companies, explains what it's all about.

Can you give us a background and description of what the referral is about?
Investigating deposits on batteries, mobile phones and other electronics was included as a commitment within the framework of the so-called January agreement between the Social Democrats, the Center Party, the Liberals and the Green Party, with the aim of Sweden having no net emissions of greenhouse gases into the atmosphere. An inquiry was set up last summer and presented its conclusions in April this year.

Deposit scheme for small electronics

The inquiry was tasked with proposing how producer responsibility for electrical equipment could be supplemented with a deposit requirement for small electronics, such as mobile phones, tablets and other small electronic equipment. The inquiry was also to propose how a national deposit system for small electronics could be designed to increase collection, reuse and recycling. The aim of the report was to increase the collection and recycling of e-waste and thus contribute to resource-efficient cycles and a circular economy.

What did the report conclude?
The report concludes that a deposit system should not be introduced as it would involve practical difficulties and burdensome administration with limited benefits. The most significant improvement for the environment is primarily an increased reuse of products. The inquiry has also shown that users point to measures other than the availability of a deposit as a key factor in increasing their submission of e-waste for recycling. The inquiry therefore believes that other measures are needed to collect small electronics, such as increased information about and increased security during collection, as well as an increased focus on preparation for reuse and recycling. This would bring greater environmental benefits at a lower cost.

Recycling must be the last stage for a product

The inquiry therefore proposes instead that the government develop and strengthen the current producer responsibility for electrical equipment. This would be more socio-economically efficient and more compatible with a circular economy than a deposit system. The report also points out that financial incentives for the collection of small electronics are being investigated at EU level and that it would be wise to await that process so that Sweden does not introduce a complicated national system that will then be adapted to a European one.

However, if a deposit system is to be established, the report suggests starting with one for mobile phones. The reasons are that they contain precious metals that are important to recycle, that there is a stockpile of mobile phones in households, that they have a relatively short lifespan and that they are consumed on a relatively large scale.

How does the industry view increased collection and recycling of electronics?
The industry is of course fundamentally extremely positive to the creation of incentives for increased collection and recycling of electronics in general and for the IT sector in particular. Electronic waste is a major global growing problem. More needs to be recycled once the technical lifetime of a product has been reached. But it is crucial to emphasize that recycling must be the final stage of a product. Increased reuse is of at least equal importance, not least of mobile phones but also other electronics.

What is the industry's position on the conclusions presented in the report?
We share and largely support the conclusions of the report as it proposes a developed and modernized producer responsibility, not the establishment of a deposit system for mobile phones. A developed producer responsibility must promote and support the ongoing development that is already taking place in the industry towards increased collection and reuse of electronics in general, not just mobile phones. We believe that this is also likely to lead to greater environmental benefits than the establishment of a deposit system. Targets, statistics and reporting requirements in this area need to be reviewed and this work must be done in collaboration with the industry. It would provide a higher value than a deposit system regardless of its design and it would be faster to implement, provide better data for future measures and thus create a better basis for political decisions in the area in the future, preferably at EU level.

But it must also be easy for customers to do the right thing, which is why reuse needs to be promoted when delivering e-waste to recycling centers. Today, all electronics are placed in a single container, the contents of which are then ground down, even though they may contain, for example, mobile phones that may have one or two life cycles left before recycling would actually be relevant. This is directly counterproductive from a sustainability perspective. It is during the production of new electronics that the industry's largest emissions are created. Ensuring that products live longer is therefore of great importance for the environment, and collection that promotes reuse is therefore absolutely fundamental to sustainable development.

What are the risks if the government were to go ahead with a deposit scheme after all?
Creating a unique, Swedish, costly deposit system for mobile phones would create unfortunate trade barriers for Swedish companies, parallel processes within the EU and impair Swedish competition. To be the first country to precede the process at EU level and introduce a Swedish national special regulation would be unwise and disadvantage both Swedish companies and consumers. It is also proposed that it is the industry that should create the system, which would take large and unnecessary resources from the ongoing work for increased reuse and circular services that the industry is driving. This without us being sure whether it leads to any direct environmental benefit.

A deposit system would also involve the pooling of large sums of money, so the risk of illegal activity is obvious obvious, e.g. in the form of illegal scrap imports. The inquiry proposes that a deposit for mobile phones should be SEK 100 per unit. Despite the fact that a deposit on PET bottles can give a maximum of SEK 2 per unit, we see crime linked to that system. It is not a very long step to believe that a deposit system for mobile phones will be abused.

What else can the industry itself do to increase the promotion of the collection of mobile phones and other IT equipment?
The industry is actively working to increase the collection of mobile phones and IT equipment, but it can of course improve on a number of things. For example, all sellers of mobile phones should be connected to approved recycling partners and offer a take-back service for data-carrying devices, and operators should also ensure better data on the flows of devices, e.g. in terms of reuse, recycling and export.

It is important to listen to what users highlight as important measures to make them feel confident about returning, for example, their mobile phones for reuse. The industry can therefore be clearer in its communication on how consumers can return devices and how all data is securely deleted, thus increasing consumer confidence and promoting collection.

A good mobile phone today can have a lifetime of at least 6-8 years. The industry can therefore also become clearer about the possibilities for repair, upgrading and trade-in systems that exist. If you want to change to a new mobile phone, there are great economic values and already today well-functioning systems for exchange, where the customer can get significantly more in compensation than the SEK 100 proposed by the investigation.

But all of this could be addressed within the framework of a modernized producer responsibility and through other targeted government mandates, and it would bring greater environmental benefits at a lower cost to both taxpayers and industry.

Any final reflections?
Yes, I would really like to emphasize the willingness of the industry to take its responsibility, through increased reuse and ultimately proper recycling. All Nordic mobile operators today offer fully circular models where you can both hand in, often for a fee, and buy used mobile phones, with the same guarantee and customer experience as for a new mobile phone. This model is also available today at the major electronics chains. The industry also offers, for example, mobile phones and other IT equipment as a service, giving the customer access to high-quality technology at a lower cost and lower carbon footprint than buying new and owning the equipment themselves.

The industry is driven not only by the desire to take its own responsibility but also by customers, who also want to reduce their footprint and take responsibility from an environmental and climate perspective. Establishing a national limited deposit system would therefore have negative consequences for the industry in terms of this positive development by creating burdensome development, administration and management of a deposit system we do not believe in, with a limited or perhaps even worse environmental benefit than today. I find it hard to believe that this is what our politicians want?

Consultation response: Use what works (SOU 2021:26)