30 April 2010 The Hon Edward Yau Secretary for the Environment Environment Bureau Dear Edward, Public Consultation on a New Producer Responsibility Scheme for WEEE The Hong Kong General Chamber of Commerce has studied the consultation document on the proposed New Producer Responsibility Scheme (PRS) for Waste Electrical and Electronic Equipment (WEEE) and would like to share our views about the proposals in the document. The Chamber supports the polluter-pay principle. We submitted position papers on waste management policy in 2002, 2003 and 2005, repeatedly urging for a comprehensive package of waste management measures. While we support PRS in principle, we have reservations on whether the scheme proposed in the consultation document could be implemented effectively. We are also concerned about the consultation document's lack of a regional and holistic solution for the WEEE problem. Our views are elaborated as follows: Market Perspective 1. Under the proposed mandatory charging scheme, consumers will either directly pay a charge for the collection and handling of WEEE, or indirectly pay when businesses pass on the cost (if it is not applied at the retail level). The Government seems to lean towards asking consumers to pay directly. But whichever option is adopted, given Hong Kong's circumstance, it will be a challenge to convince the consumers to pay. At present, the majority of WEEE is collected by second-hand dealers for a small fee, or disposed by retailers as a service to customers. Consumers will feel hard done by if they have to pay for a service that is free all along, or, even worse, something they can practically sell to the dealers (even though the price is minimal). 2. With the collected fees, the government would appoint contractors to handle WEEE. While the Chamber agrees to enhance the regulations for the collection and handling of WEEE, we are concerned that the government appointed and funded contractors would dominate the market and crowd out the existing small recyclers and second-hand dealers. A balance has to be struck while the government tries to scale up the WEEE-related business sector, so that the existing trader will be able to survive if they comply with the tightened standards. Before a viable WEEE recycling/reuse business model is established, it may be necessary for the government provide subsidy. But the government must commit to finding a market solution in the long run, which, in our view, would only be possible with regional cooperation. Regional Perspective 3. The government only seeks to regulate and fund the collection and handling of WEEE, which represents just one aspect of a possible comprehensive solution to. But where would the collected WEEE go? Would the waste be re-processed or recycled into reusable materials? From a supply chain or regional perspective, which is lacking in the consultation document, we have the following questions: - How can we turn WEEE into useful resources and put it back into the manufacturing supply chain that services Hong Kong's market? - If our so-called solution is not just about exporting our waste to others, what are the opportunities for working with the Pearl River Delta (PRD), which has a vast manufacturing base, to come up with a regional solution for turning waste into usable materials? - Apart from focusing on downstream measures, what can be done upstream to minimise waste? How should green labelling, green procurement and design for the environment (DfE) be incorporated into the solution for WEEE? 4. The Chamber envisions that it requires the development of a regional circular economy to fundamentally resolve the WEEE problem and - perhaps more importantly - to capture opportunities in building up a green manufacturing supply chain in partnership with the PRD. A consultancy study was commissioned by the Chamber to look at possible models for a circular economy in the region, and a copy of the study report has been submitted with you not long ago. We believe our study report will provide a much-needed perspective for the community's discussion on WEEE and the wider challenge of working with the PRD to improve the environment and develop the green industries. I look forward to having more in-depth discussion with you on the subject. Thank you very much. Warm regards Yours sincerely Alex Fong CEO
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