2020 UN ESCAP-SINGG project

Sustainable Management Plan of

E-waste in Bangladesh

Final Report

December, 2020
 Table of Contents

List of Tables ..................................................................................................... vi

List of Figures ................................................................................................. viii
List of Acronyms ................................................................................................x

Executive Summary ........................................................................................ xii

1 Introduction ..................................................................................................1
1.1 Background ........................................................................................................... 1

1.2 Objectives ................................................................................................................ 3

1.3 Methodology ........................................................................................................... 3

2 Current status and issues of E-waste management in Asia

and other countries ..................................................................................... 5

2.1 Current problems and issues in E-waste management ............................................ 5

2.1.1 Increasing amount of E-waste ..................................................................... 5

2.1.2 Environmental and public health risks from the E-waste stream ............... 6

2.1.3 Informal sectors as major actor ................................................................... 7

2.1.4 Transboundary movement of E-waste ........................................................ 8

2.2 Current status of E-waste management in Asia ....................................................... 9

2.2.1 India ............................................................................................................ 9

2.2.2 China ......................................................................................................... 16

2.3 Transboundary movement: International legal frameworks applicable to

E-waste management (focused on Basel Convention) .......................................... 19

2.3.1 Objective and provisions of Basel Convention ......................................... 20

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 2.3.2 The scope of hazardous waste of Basel Convention ................................. 22

2.3.3 Classification E-waste in Basel Convention ............................................. 23

2.3.4 E-waste management under Basel Convention......................................... 24

2.3.5 Control of transboundary movement of waste in Bangladesh .................. 27

3 The current situation on managing E-waste in Bangladesh .................... 30

3.1 Evaluation of the current regulatory framework on managing

E-waste in Bangladesh .......................................................................................... 31

3.1.1 Outline in relevant laws ............................................................................ 31

3.1.2 Hazardous Waste (E-waste) Management Rules (Draft) of 2019 .............. 34

3.2 Previous studies: Baseline situation of E-waste generation in Bangladesh .......... 40

3.2.1 E-waste generation predicted from previous studies ................................ 40

3.2.2 E-waste generation by devices .................................................................. 44

3.3 Analysis of current problems and main challenges for managing E-waste .......... 49

3.3.1 Environmental pollution by improper E-waste management ................... 49

3.3.2 Absence of proper regulatory framework ................................................. 51

3.3.3 Absence of partnerships with stakeholders ............................................... 54

3.3.4 Environmental awareness on E-waste ...................................................... 56

3.3.5 Financial security ...................................................................................... 57

3.3.6 SWOT (strength/weakness/opportunity/threat) analysis of

E-waste management in Bangladesh ........................................................ 58

4 International efforts and implications on sustainable management of

E-waste ....................................................................................................... 62
4.1 Sustainable E-waste management in advanced countries ..................................... 63

4.1.1 USA........................................................................................................... 63

4.1.2 European Union and member states ......................................................... 64

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 4.1.3 Japan ......................................................................................................... 68

4.2 Eco-Assurance System for E-waste management in Korea .................................. 72

4.2.1 History on E-waste management in Korea ............................................... 72

4.2.2 Management of waste by EPR system ...................................................... 73

4.2.3 Management of E-waste by Eco-AS ......................................................... 77

4.2.4 Materials and financial flow on E-waste management in Korea .............. 79

4.3 Implications of sustainable E-waste management ................................................. 81

4.3.1 Implication on E-waste management in Asian countries .......................... 81

4.3.2 Policy design for E-waste management .................................................... 84

4.3.3 Capacity building on E-waste management through ESM ....................... 87

4.3.4 Sustainable development of E-waste management with

international cooperation .......................................................................... 88

4.3.5 Raising awareness on E-waste management............................................. 90

5 Sustainable management plan of E-waste in Bangladesh ..................... 92

5.1 Overview ............................................................................................................... 92

5.2 Suggestions for E-waste management in Bangladesh ........................................... 92

5.2.1 Suggestions of E-waste management system ........................................... 92

5.2.2 Responsibilities and roles of stakeholders towards sustainable

E-waste management ................................................................................ 94

5.2.3 Establishment of collection system and its managing association............ 96

5.3 Introduction to Pre-EPR policy and system in Bangladesh .................................. 96

5.3.1 Definition and concepts of Pre-EPR ......................................................... 97

5.3.2 Objectives and principles of Pre-EPR system ........................................ 100

5.3.3 Policy design for Pre-EPR system .......................................................... 101

5.3.4 Proposed management system of E-waste by Pre-EPR .......................... 104

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 5.3.5 Role and responsibility of relevant stakeholders .................................... 105

5.3.6 Establishment of producers and recyclers associations .......................... 108

5.3.7 Recycling annual targets, cost contribution and penalty of

E-waste: Example ................................................................................... 109

5.3.8 Establishment of partnerships among stakeholders under Pre-EPR ........115

5.3.9 Public awareness on E-waste by Pre-EPR sytsem ...................................117

5.3.10 Expected outcomes and benefits of Pre-EPR .........................................117

5.4 International cooperation on E-waste recycling technology transfer and

training program .................................................................................................119

5.4.1 Applications of appropriate E-waste recycling technology by

international cooperation .........................................................................119

5.4.2 Training program of E-waste management ............................................. 125

6 Conclusions and recommendations ....................................................... 129

6.1 Summary and conclusions ...................................................................... 129

6.2 Recommendations ................................................................................... 130

6.3 Limitations and future directions ............................................................ 131

References ...................................................................................................... 134

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List of Tables

Table 2-1. Examples on classification of E-waste under the Basel Convention .................... 24

Table 2-2. Principles and elements of EPR system................................................................ 26

Table 3-1. The specific items mentioned in Schedule 1 of Hazardous Waste

(E-waste) Management Rules (Draft) of 2019..................................................... 35
Table 3-2. Roles and responsibilities of stakeholders in E-waste management Rules .......... 38

Table 3-3. Target rates for E-waste collection by manufacturers, assemblers, and
large importers in Schedule-2 in E-waste rules ...................................................... 39
Table 3-4. Estimated generation of E-waste in Bangladesh................................................... 42

Table 3-5. Summary of estimates of E-waste item amounts in Bangladesh from

previous studies ...................................................................................................... 45

Table 3-6. Total amounts of E-waste recycling sectors in Bangladesh .................................. 46

Table 3-7. E-waste recycling companies licensed by environmental clearance

in Bangladesh ......................................................................................................... 47
Table 3-8. Heavy metal concentrations (mg/kg) in soils near the waste processing site in
Dhaka, Bangladesh, evaluated through triplicate sampling at five sites.................. 50
Table 3-9. Summary of the SWOT analysis for E-waste management in Bangladesh .......... 59

Table 4-1 Target recycle and recovery rate by WEEE category in EU .................................. 66

Table 4-2 Comparison of E-waste management systems in advanced countries................... 70

Table 4-3. EPR system and target items ................................................................................ 75

Table 4-4. Obligation rates and recycling rate in EPR system .............................................. 76

Table 4-5. Recycling targets and recycled amount of E-waste by Eco-AS ........................... 79

Table 4-6. A review of E-waste management issues and solutions

in Asian countries by research aspect and geographic region. .............................. 83

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Table 4-7. The method of Pre-EPR system ........................................................................... 86

Table 5-1. Responsibilities and roles of stakeholders in E-waste management .................... 95

Table 5-2. The implementation methods of Pre-EPR policy ............................................... 103

Table 5-3. Roles and responsibilities of stakeholders in Pre-EPR for E-waste ................... 107

Table 5-4. Recycling unit cost and mass composition of E-waste (example) ......................114

Table 5-5. Typical collection system of E-waste ................................................................. 121

Table 5-6. Benefit and issue of pre-treatment of E-waste .................................................... 122

Table 5-7. Benefit and issue of material recovery of E-waste ............................................. 124

Table 5-8. Composition of general training materials ......................................................... 127

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List of Figures

Figure 2-1. Formal E-waste recycler in India .........................................................................11

Figure 2-2. Dismantling E-waste by child in informal sector in India .................................. 12

Figure 2-3. Existing E-waste trade system flows in India ..................................................... 14

Figure 2-4. Proposed E-waste management system for India................................................ 15

Figure 2-5. The flow of taxes by EPR system in China......................................................... 18

Figure 2-6. Wastes subject to control in the Basel Convention ............................................. 22

Figure 3-1. A brief history of the development of environmental law in Bangladesh ........... 32

Figure 3-2. Summary and weakness of new E-waste rules ................................................... 54

Figure 3-3. An example of the current E-waste recycling practices in Bangladesh. ............. 56

Figure 4-1. Map of states with E-waste legislation in USA .................................................. 64

Figure 4-2. WEEE management flow in Germany ................................................................ 67

Figure 4-3. E-waste flow in Japan ......................................................................................... 70

Figure 4-4. History on E-waste management in Korea.......................................................... 73

Figure 4-5. Summary of the Eco-Assurance System (Eco-AS) ............................................. 78

Figure 4-6. Materials and financial flow on E-waste management in Korea ........................ 81

Figure 5-1. Suggestion on E-waste management system in Bangladesh ............................... 94

Figure 5-2. Concept of EPR policy ........................................................................................ 98

Figure 5-3. E-waste management by formal and informal sectors in developed and
developing countries ............................................................................................ 99

Figure 5-4. Concepts of Pre-EPR and full-scale EPR............................................................ 99

Figure 5-5. Objectives of Pre-EPR policy for E-waste in Bangladesh ................................ 100

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Figure 5-6. Management system of E-waste by Pre-EPR in Bangladesh ............................ 105

Figure 5-7. Establishment of communication and partnerships among stakeholders by

Pre-EPR in Bangladesh .................................................................................... 116
Figure 5-8. Partnership between Vietnam and Korea .......................................................... 125

Figure 5-9. Examples of training programs for E-waste in other countries......................... 128

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 List of Acronyms

Acronym Official name

3R Reduce Reuse Recycle

CE Circular Economy

CERM Centre for Environmental and Resource Management ,BUET

DOE Department of Environment

ECC Environment Clearance Certificate

Eco-AS Eco-Assurance System

EEE Electrical Electronic Equipment

ELVs End-of-Life Vehicles

EPR Extended Producer Responsibility

ESDO Environment and Social Development Organization

ESM Environmentally Sound Management

EU European Union

ICT Information & Communication Technology

KERC Korea Electronic Recycling Association

MOEFCC Ministry of Environment , Forest & Climate Change

Korea MOE Ministry of Environment of the Republic of Korea

Pre-EPR Preliminary Extended Producer Responsibility

PRO Producer Responsibility Organization

RoHS The Restriction of the use of certain Hazardous Substances

SDG Sustainable Development Goal

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SINGG Seoul Initiative Network on Green Growth

S.R.O Statutory Regulatory Order

SWOT Strength Weakness Opportunity Threat

UN ESCAP United Nations Economic and Social Commission for Asia and the Pacific

WEEE Waste Electrical Electronic Equipment

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 Executive Summary

Research background

1. Bangladesh, with a population of over 160 million people, has a high environmental

pollution loading due to high population density, urbanization, and rapid economic

and technological development. Such economic growth with emerging market for

consumer goods has created the needs for enormous amounts of natural resources,

imports and exports, and energy in the country. Among the consumer products,

electrical and electronic equipment has become an essential products in our modern

digital society. As information & communication technology (ICT) and electronic

technology develop fast, the widespread use and replacement of such devices and

equipment is commonly found in everyday life. Once electrical and electronic

products reach end-of-life, they become waste electrical and electronic equipment

(WEEE) or often called electronic waste (e-waste). Waste electrical and electronic

equipment encompass a wide range of electrical and electronic waste products,

including home appliances (e.g., refrigerators, washing machines, air conditioners);

information technology and telecommunication equipment (e.g., personal computers,

laptop computers, printers, copying equipment, calculators, facsimiles, telephones,

mobile phones); consumer electronic devices (e.g., televisions, radios, video cameras,

audio equipment); and other medium- and small-sized electrical and electronic

equipment (e.g., air and water purifiers, vacuum cleaners, toasters, coffee machines,

hair dryers, watches, or irons). Such waste can be processed to recover valuable

resources (e.g., copper, aluminum, silver, gold) or be sources of toxic elements to the

environment and human health, if it is improperly treated upon disposal. Thus, the

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 recycling and management of E-waste has become a major environmental issue of

concern for the solid waste communities in Bangladesh and around the world. In

recent years, ‘the National 3R Strategy For Waste Management’ was prepared with

the assistance of UNCRD and to address the emerging problem of E-waste. UN-

ESCAP came forward to develop this Sustainable E-waste Management Plan for

Bangladesh.

2. This study deals with current efforts and issues on E-waste management in

Bangladesh and other countries. It also analyzes the exiting legal framework, policy,

and the current situation on managing the waste in Bangladesh. Based on the

comparative analysis, it develops a sustainable E-waste management plan and makes

policy recommendations for the new E-waste rule with an emphasis of extended

producer responsibility (EPR). This study focuses on in-depth analysis of E-waste

management problems and challenges in Bangladesh as well as other countries that

commonly adopt EPR. Rudimentary recycling and open burning practices of E-waste

are still common in Bangladesh. As a result, a large amount ends up in landfills and

the environment. Proper recycling of E-waste is crucial to resource recovery as well

as environmental conservation in Bangladesh. EPR policy has the potential to play an

important role in E-waste recycling and management.

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Research objectives

3. The aim of this study is to develop a sustainable E-waste management plan in

Bangladesh. It explores the existing legal frameworks and current issues and

problems of E-waste in Bangladesh as well as other countries. It identifies some

challenges and weaknesses of current E-waste management, and opportunities and

needs for Pre-EPR (Preliminary EPR). In particular, the detailed Pre-EPR concept

and policy design are suggested for an initial step since the full-scale EPR commonly

adopted by advanced countries may be ineffective in situation where informal sectors

have been firmly established in Bangladesh. Full-scale (or full-fledged) EPR can be

implemented as the Pre-EPR system is steadily operated and accustomed.

Research Findings

Current issues related E-waste management in Asia and other countries

4. Large quantities of E-waste generation in Asian countries including Bangladesh have

become an issue of concern. In a recent report, it was estimated that approximately

24.9 million of E-waste from Asia out of 53.6 million tons in the world was

generated in 2019. Such waste is commonly recycled in informal sectors without

proper safety equipment in many developing countries. As a result, it causes a severe

threat to human health and the environment during the recycling process of E-waste.

Open burning and dumping in landfills of E-waste result in contamination of soil,

water, and sediment by leaching of heavy metals and organic pollutants commonly

present in such waste. Numerous studies reported that high concentrations of toxic

metals and polybrominated diphenyl ether (PBDEs), polybrominated dibenzodioxins

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 and furans (PBDD/Fs), polychlorinated dibenzodioxins and furans (PCDD/Fr) in air,

dust, sediments, and freshwater were found near the E-waste recycling and dumping

sites.

5. In addition, a large volume of E-waste is imported illegally into developing countries

in the name of second-hand electrical and electronic equipment management. Since

most E-waste is classified as hazardous waste under the Basel Convention, the

transboundary movement of hazardous waste is prohibited. When transboundary

movement of E-waste as non-hazardous waste is permitted, official inspection or

supporting documents must be required and attached. The Basel Convention

recommends the application of EPR for the management of various wastes, including

E-waste through Environmentally Sound Management (ESM) approach.

Current situation on managing E-waste in Bangladesh

6. The Hazardous Waste(E-Waste) Management Rules(Draft) 2019 is being finalized

for proper management of E-waste in Bangladesh. The main aim of this rule is to

regulate the management of E-waste in an environmentally sound manner under

mother law, the Environmental Conservation Act (1995). The rule presents the scope

and responsibilities of stakeholders with a concept of EPR, collection targets,

registration of E-waste management, restricted use of toxic substances in electronics,

and the prohibition on imports of used electrical and electronic products.

7. Several previous studies investigated E-waste management problems and issues in

Bangladesh. Environmental concerns from the final disposal activities of E-waste

were raised by the researchers. The informal sectors largely process E-waste in a

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 rudimentary way, causing health risks to humans and environmental pollution due to

improper disposal.

8. Many informal recycling sites perform open burning of wires/cables to recover

copper, resulting in the release of harmful compounds like dioxins, furans, and heavy

metals. Health impacts for employees at E-waste recycling sites by using risk

assessment were reported by the studies. Reliable inventory of E-waste is still needed

with material flow analysis, since the generation rates widely varied depending on

the studies. There is a lack of building partnerships among stakeholders including

private recyclers, producers, distributers, consumers, and government to bring all

actors to the table of E-waste management. According to one of the studies, more

than 90% of households in Bangladesh were not even aware of the terminology “E-

waste.” Raising public awareness of environmental issues for households and

consumers is also crucial for collection and recycling of E-waste.

International efforts and implications on sustainable management of

E-waste

9. In advanced countries such as EU countries, Japan, and South Korea, regulatory

measures have been strengthened to properly manage E-waste by restricting the use

of hazardous substances in Electrical and Electronic Equipment (EEE), curbing the

generation of hazardous waste, and giving producers the responsibility of the

collection and recycling.

10. In European Union (EU), both WEEE Directive in 2003 and the Directive on the

Restriction of the use of certain Hazardous Substances (RoHS) in EEE for the

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 environmentally sound management of WEEE have been promulgated. Under the

WEEE Directive, producers (i.e., manufacturers and importers) of EEE are required

to collect and treat WEEE using environmentally sound management methods. The

RoHS Directive aims to reduce the environmental impact of E-waste by restricting

the use of certain hazardous substances (e.g., heavy metals, brominated flame

retardants, and phthalates) in EEE to prevent adverse effects on human health and the

environment during the collection, recycling, recovery, and disposal of WEEE. By

the WEEE Directive, the recycling target for WEEE was set to a range of 55% to

80%, while the recovery target was set to a range of 75% to 85%, depending upon

the category.

11. In Japan, the Home Appliance Recycling Act and Small E-waste Recycling Act have

been implemented. The Home Appliance Recycling Act covers 4 items of E-waste

(e.g., televisions, washing machines, air conditioners, and refrigerators) and sets a

target recycling rate of 55% to 82% by weight for each item, while the Small E-waste

Recycling Act covers 28 categories of small-sized E-waste items and sets the

collection target to 140,000 tons by 2020. The laws require producers to create take-

back system to collect and recycling E-waste.

12. In South Korea, the EPR system was introduced in 2003 by establishing Producer

Responsibility Organizations (PROs) to take responsibility for producers for

collection and recycling of E-waste starting with large household appliances (e.g.,

refrigerators, TVs, washing machines, and air-conditioners). In 2014, the Eco-

Assurance System (Eco-AS) was adopted for pollution prevention as well as

recycling, covering 27 recycling target items such as medium and small-sized

electrical and electronic products. In 2020, the recycling target items of the Eco-AS

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 were expanded to up to 50 items by four categories, including internet routers, solar

panels, and many others. The obligation amount for E-waste recycling target was

increased from 3.9 kg per capita in 2014 to 7.0 kg per capita in 2020.

13. In most advanced countries, policy and management system based on the EPR

concept is commonly in place to manage E-waste. It indicates that designing an EPR

system with clear and well-defined roles is essential for all actors including

producers, consumers, authorities, and waste managers. Producers and distributers

usually take responsibilities for collection and recycling of E-waste by achieving

target collection and recycling rates assigned by government, while it is properly

disposed of by consumers. Penalties can be imposed, if they do not meet their target

rates. The target rates often continually increase and are annually set by considering

domestic demands of EEE and recycling market condition and infrastructure.

Development of Sustainable E-waste Management Plan for Bangladesh

14. A sustainable E-waste management plan in Bangladesh was developed with a Pre-

EPR concept and policy by considering economic, social, and cultural contexts in

Bangladesh. Although the new rule of E-waste indicates the EPR concept with

responsibility of stakeholders and collection target rates, the establishment of full-

scale or full-fledged EPR commonly adopted to that in advanced countries can be a

challenging task for Bangladesh.

15. By adopting Pre-EPR policy and measures could help to improve E-waste recycling

in three ways. First, they could help improve the implementation of a new E-waste

rule, and he integration of EPR into environmental and circular economy objectives

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 (e.g., through wide application of EPR to other products). This would contribute to

reducing open burning and landfilling of E-waste and recovering valuable resources

from it. Second, the Pre-EPR could financially support the formal sector under the

supervision of DOE. This could be developing clear responsibilities and roles

between stakeholders, ensuring cost contribution by producers, proper treatment by

recyclers, and transparency on the performance and material and financial flows.

Third, changes to the Pre-EPR could strengthen the financial incentives for collectors,

recyclers, and consumers in the formal sector. Appropriate economic incentives

should be developed to divert E-waste away from the informal sectors, flavoring into

the formal sector for proper treatment.

16. Thus, in this study, Pre-EPR concept and policy directions are suggested by taking

step by step and streamlined approaches in Bangladesh. The several policy designs

for Pre-EPR as a major part of the management plan are as followings:

A. Objectives: The objectives of Pre-EPR policy in Bangladesh include the design of

material and financial flows of sustainable E-waste management, the development

of E-waste recycling target rates to be achieved annually, the build-up of

supporting E-waste recycling by formal sector, the establishment of partnership

among stakeholders, and the effective implementation of the proposed E-waste

rule.

B. 3P Principles: Polluters (i.e., producers, including importers) pay principle (3P) is

applied to cover the cost of collection and recycling of E-waste by diverting from

open burning and landfilling.

C. Environmentally Sound Method (ESM): All practicable steps to ensure that E-

waste is managed in a sound manner will protect human health and the

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 environment against the adverse effects that may result from improper disposal of

such waste.

D. Recycling target rate: Under the Pre-EPR system, producers (i.e., manufacturers

and importers) should annually collect and recycle their assigned quantities

corresponding to the mandatory recycling rate (kg/person/year) notified by the

DOE, MOEFCC based on annual sales data.

E. Establishment of PRO: In order to divert current informal collection flow into the

formal flow, producer association (i.e., producer responsibility organization, PRO)

or managing association should be established initially by producers (i.e.,

manufacturers and importers) of electrical and electronic equipment under the Pre-

EPR system.

F. Contribution cost by producers: By taking the approach of Polluters Pay

Principle, producers can fulfill their obligations by joining to the PRO or by taking

their individual obligations by collecting and recycling E-waste via take-back

scheme or Exchange Program . In the case of producers who join the PRO, they

can fulfill the recycling obligations by paying their contribution fee to the PRO.

The cost of the contribution is annually determined by the PRO under the

supervision of government officials, based on collection and recycling costs.

G. Penalties for producers: Producers who fail to meet their recycling obligations

will have to pay fines more than the recycling cost of E-waste.

H. Financial support for collectors and recyclers in formal sectors: The PRO

provides the subsidies to the collectors and recyclers of E-waste to act on the

producer’s obligations. The collectors and recyclers can carry out collection and

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 recycling operations with the subsidies received and usually contracts with the

PRO.

I. Reporting of collection and recycling to DOE: Both the PRO and the association

of recyclers should submit an annual report on the collection and recycling

performance directly to the DOE or other third party (e.g., Environmental

Cooperation) under the Bangladesh MOE authorized by the MOEFCC.

17. The Pre-EPR system is designed for establishing E-waste recycling in an

environmentally sound manner by financially supporting early-stage formal sector

industry. There will be a competition of E-waste recycling between the formal sectors

and the informal sector under the Pre-EPR system. Thus, the material flow of E-

waste into the informal sector should be discouraged by using economic incentives

and strengthened regulations by adopting Pre-EPR policy, flowing into the formal

sector. The management of E-waste should be sustainable to protect to the

environment and human health. In order to properly manage E-waste, sharing of

experiences, information exchanges, and technical supports from advanced countries

such as EU countries, Korea and Japan are also strongly encouraged by international

cooperation.

18. It should also be noted that the Pre-EPR does not function in a vacuum, and other

policy instruments such as incentives or disposal fee of E-waste, voluntary

agreements with industry, awareness campaigns and education should be

accompanied. Responsible activities of source separation and product choices by

consumers are also crucial.

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 19. According to the waste management hierarchy, reduce and reuse is more preferred

options than recycling and treatment. For this reason, the Pre-EPR system does not

interfere any actions related to reuse or prevention. Reuse and prevention activities

for consumers and citizens are also strongly encouraged by the government since the

Pre-EPR plays an important role of recycling and treatment.

Conclusion

20. Based on the results of this research project, the following conclusions are made.

Throughout the report, the importance of recognizing the roles and shared

responsibilities of producers, collectors and recyclers in life cycle of electronic

products has been emphasized. This report also highlights the analysis of EPR

system commonly adopted by advanced countries, focusing on the development of

sustainable management plan of E-waste in Bangladesh by considering local

conditions, and socio -economic conditions. EPR is a vital part of E-waste

management to support the transition from recycling of the informal sector to the

formal sector towards a sustainable circular economy.

(1) Issues and problems related to E-waste management. Several issues and

problems of concern related to E-waste management in Bangladesh includes

severe environmental pollution, toxic hazards to recyclers in informal sectors,

loss of recoverable resource, and lack of legal frame and environmental

awareness for public.

(2) Analysis of the Existing legal framework and regulations. Although the Draft

Hazardous Waste (E-waste) Management Rules is waiting for final approval of

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 inter-ministerial meeting, proposed legal frame and regulations are still lack of

recycling target rates for producers, mechanism of financial and material flows,

economic incentives and penalties, and detailed implementation methods and

strategy.

(3) Summary of International Efforts on E-waste in advanced countries. Many

advanced countries adopted EPR systems for E-waste collection and recycling

with target goals and economic incentives. Producer responsibility organization

is commonly formed to take a joint responsibility for producers and financially

support collectors and recyclers. Full or partial responsibility and role of each

stakeholder in the full life cycle of electronic products is clearly stated upon E-

waste recycling.

(4) Development of Sustainable Management Plan for E-waste in Bangladesh:

The sustainable management plan of E-waste in Bangladesh emphasized Pre-

EPR system with national recycling target rates for limited number of target

electronic devices, financial and material flows, the roles and responsibility of

stakeholders, the establishment of effective partnerships and environmental

awareness by consumers. This study suggests that there is a need for

collaboration with the formal sector and Department of Environment(DOE).

They should work more closely with the sector to solve the E-waste disposal

problems.

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Recommendations

21. The Department of Environment(DOE) as a regulatory body of Ministry of

Environment, Forest & Climate Change(MOEFCC) will implement the Sustainable

E-waste Management Plan as a custodian of Hazardous Waste (E-waste)

Management Rules 2019 (Draft). When the e-waste management plan is

implemented, the following recommendations are made:

(1) Understand and communicate how the Pre-EPR works, as a part of E-waste

Management Plan. The DOE should understand how the Pre-EPR works and

interacts with other policy initiatives, such as E-waste import ban and Basel

Convention, and the potential benefits it can be derived.

(2) Establish Pre-EPR system with limited recycling target items. Pre-EPR

system should be initially established for supporting E-waste recycling by the

formal sector with national recycling target rates. It is then followed by full-scale

EPR as the system is properly operated along with expanded target recycling

items and increased recycling target rates of E-waste.

(3) Set-up national recycling target rates under the Pre-EPR system with limited

items. TVs and other electrical and electronic devices (e.g., mobile phones,

refrigerators, washing machines) are recommended for recycling target items

under the Pre-EPR system. Recycling target rate of E-waste can be annually

evaluated with socio-economic infrastructure. The streamlined approach with

limited target items would give more insight into the formulations of the target

rates, Leading to the establishment of Producer Responsibility Organization (PRO)

and association of E-waste recyclers having a joint work plan.

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(4) Establish partnership, coordination and governance among stakeholders:

Upon the establishment of Pre-EPR system, partnerships, coordination, and

governance among the stakeholders (i.e., producers, collectors, recyclers, NGO,

consumers, government, PRO) would be crucial with clear roles and

responsibility for E-waste collection and recycling. PRO and association of E-

waste recyclers from the formal sector should be established to compete the

informal sectors and take the responsibility for the national recycling target rate.

(5) Communicate with stakeholders with clear responsibility under the Pre-EPR

system. Department of Environment(DOE) should communicate their

responsibilities with stakeholders clearly under the Pre-EPR. and emphasize that

each stakeholder should play an important role of E-waste collection and

recycling.

-xxv-
1 Introduction

1.1 Background

The Seoul Initiative Network on Green Growth (SINGG) was proposed by the

Ministry of Environment of the Republic of Korea (Korea MOE) at the fifth Ministerial

Conference on Environment and Development in Asia and the Pacific (MCED-5) in 2005 and

endorsed by 61st UN ESCAP Commission Session. The objective of SINGG, which is now in

phase III, is to enhance the ability of countries in Asia and the Pacific to develop and

implement green growth strategies in support of the 2030 Agenda achievement as well as the

implementation of the Paris Agreement. Moreover, the themes of the activities consist of

environment-related Sustainable Development Goals (SDGs) including the promotion of

green finance and emerging innovative instruments to support the environmental

sustainability of member states (Project Document of Seoul Initiative Network on Green

Growth Phase III). In this context, UNESCAP, in cooperation with Korea MOE, has

implemented several pilot projects that UNESCAP, selected one country each year and

supported its implementation of green and inclusive strategies in addressing its facing

environmental issues. In 2019, Bangladesh was selected as a target country through

consultation between Korea MOE, UNESCAP, and the Department of Environment of

Bangladesh(DOE). The Bangladesh DoE had submitted its proposal for the pilot project of

SINGG to resolve its issues for managing electronic waste (E-waste), which is one of the

most urgent issues of concern in Bangladesh. The DoE requested UNESCAP to support them

in developing National Strategy for E-waste management to set up the management system in

the country.

In Bangladesh, large amounts of E-waste are generated every year. Of this amount, only

20 percent is recycled, and the rest of the waste is released into landfills, rivers, drains lakes,

１
open spaces, which are very hazardous for the health and environment (Alam et al., 2015). In

2011, the Ministry of Environment and Forest & Climate Change (MoEFCC) and the DoE

had prepared a draft regulation entitled, “Hazardous Waste(E-waste) Management Rules”

which will be implemented after enactment. There are several drawbacks in the current

practices of E-waste in Bangladesh, including to lack of adequate legislation and regulation.

Environmentally sound management of such waste is a challenging task because of the

absence of relevant inventory of E-waste, lack of environmental awareness of various

stakeholders, and hazardous conditions of the informal recycling sectors. E-waste is one of

the fastest-growing environmental problems worldwide, especially in middle- and low-

income countries. It would also be the challenge for the Member States in achieving the

Sustainable Development Goals(SDGs), particularly relating to target 3.9, 8.3, 8.8, 11.6, 12.4

and 12.5 (UN EMG, 2017). In this regard, the purpose of this research is to support

Bangladesh in achieving related SDGs targets by implementing a relevant E-waste

management system. The outcomes of the research project would be able to apply to other

countries in Asia and the Pacific that have difficulties and challenges in managing E-waste

like Bangladesh.

It is very essential to undertake the research and analysis of the current challenges and

limitations based on thorough understanding of the field status to design a proper

management plan of E-waste in Bangladesh. This report deals with current issues and

problems related to E-waste management in middle- and low-income countries (i.e., India,

China, and Bangladesh), the analysis of the existing legal framework, policy of E-waste

management in Bangladesh, and current efforts on sustainable management of E-waste in

Korea, Japan, and India. Several implications and suggestions for proper E-waste

management are made, based on the analysis of extended producer responsibility (EPR) and

management systems. Finally, sustainable management plan of E-waste in Bangladesh is

２
developed with focusing on Pre-EPR(Preliminary EPR) with governance and partnerships

among stakeholders.

1.2 Objectives

The objectives of this study are as followings.

(1) Assess the current status of management of E-waste in Bangladesh through

research on literature, analysis of statistics, and communication with local
experts.

(2) Conduct in-depth research on the measures by the Bangladesh government to

manage E-waste, including laws, policy directions and efforts, and examine the
effectiveness of stakeholders and E-waste management as the result of
implementing each measure.

(3) Examine current efforts on sustainable E-waste management in other countries

including Korea, Japan, EU countries, and India) to draw implications and
suggestions for better E-waste management in Bangladesh.

(4) Finally, present the development of sustainable E-waste management plan in

Bangladesh with roles and responsibility of stakeholders, Pre-EPR system, and

implementation strategy.

1.3 Methodology

The methodology for this study has been to undertake an initial literature review and

research into existing E-waste recycling by EPR schemes in a variety of countries. In-depth

studies on EPR schemes and system of E-waste from several countries such as Korea, India,

China and Japan have been conducted to draw implications and suggests for E-waste

recycling in Bangladesh.

３
 The project team has been supported by local experts and DOE. In addition, a group of

DOE were invited to an expert roundtable meeting during the study and fed their thoughts

into the development of sustainable E-waste management plan and the recommendations.

In addition to this report, a separate policy brief is also available to describe

comprehensive policy design of E-waste recycling by the proposed Pre-EPR system in

Bangladesh.

４
 2. Current status and issues of E-waste management in Asia
and other countries

2.1 Current problems and issues of E-waste management

2.1.1 Increasing amount of E-waste

Globally, approximately 53.6 million tons of E-waste was generated in 2019 (Forti et

al., 2020); by 2030, it is estimated that the amount of E-waste generation will reach up to 75

million tons (Forti et al., 2020). Of the 53.6 million tons, approximately 9.3 million tons is

reported to enter the collection and recycling pathways; the flow of the remaining E-waste is

unknown and likely dumped, traded, or recycled in a non-environmentally sound manner

(Baldé et al., 2017; Forti et al., 2020). E-waste entering the unknown route can cause

significant negative effects to human health and the environment via improper and unsafe

treatment and disposal such as open burning or dumping (Ikhlayel, 2018). In addition, if

proper management of such waste is not carried out during its transboundary movement, the

hazardous substances in E-waste can lead to accidents such as fires (Terazono, 2018). Since

the annual growth rate for the E-waste streams had been estimated to be 3-5% (Cucchiella et

al., 2015)—about three times faster than other waste streams (Singh et al., 2016)—the future

E-waste problems may become a more imminent burden. It should be noted that estimated

amounts of E-waste generation pose some degree of uncertainty as its inventories were not

fully documented in many countries. Insufficient and unreliable inventories of E-waste

generated from different countries is one of the major barriers blocking sustainable

environmental management of the waste around the world.

５
 As summarized by Kumar et al. (2017), E-waste generation quantities are often

determined using estimation frameworks, including the sales obsolescence method (Miller et

al., 2016; Tran et al., 2016), survey scale-up method, hybrid sales obsolescence-trade data

method (CEC, 2016), and mass balance method. These tools utilize variables related to a

nation's demographics and socio-economic contexts such as consumption patterns, disposal

behaviors, collection and recycling infrastructure, and environmental awareness, etc.

2.1.2 Environmental and public health risks from E-waste stream

E-waste stream is becoming a severe threat to both the environment and public health.

Hazardous materials (e.g., heavy metals and organic toxic pollutants such as polybrominated

diphenyl ethers) in the waste can be released into the surrounding environment at its final

disposal site or through improper recycling practices. Released components spread through

the atmosphere or water bodies, and are consequently introduced into society. Labor-

intensive recycling practices of the waste use primitive technologies that may directly harm

workers by exposing them to high concentrations of contaminants.

Open dumping of E-waste without proper management or recycling often results in

contamination of the nearest soil environment or receiving water bodies connected to the

groundwater flow path. Many solid waste landfills in low-income countries are operated

without engineered landfill liners. Therefore, leachates containing toxic substances from E-

waste can enter and flow with groundwater. As summarized by Garlapati (2016), E-waste

may contain many types of hazardous compounds or chemicals including halogenated

organic compounds and heavy metals. Such toxic substances could increase the risk of both

acute and chronic diseases through exposure to humans.

６
 To recover precious materials from E-waste, open burning is widely applied in many

developing countries. As a result, high levels of pollutants can be spread near E-waste

recycling sites. Brigden (2005) revealed that the environment had been contaminated at many

E-waste recycling sites in China and India, evidenced by high concentrations of lead,

polybrominated diphenyl ethers (PBDEs), polybrominated dibenzodioxins and furans

(PBDD/Fs), polychlorinated dibenzodioxins and furans (PCDD/Fr) in air, dust, sediments,

and freshwater near sites. Many scientific articles have highlighted the impacts of

contamination on humans near E-waste recycling sites, evidenced by increased heavy metal

concentrations in the hair (Zheng et al., 2011), elevated concentrations of heavy metals in

urine (Wang et al., 2011), and detection of polychlorinated biphenyls and brominated flame

retardants in women’s breast milk (Tue et al., 2010) among others.

2.1.3 Informal sectors as major actor

Unlike high-income countries, large proportions of E-waste in middle- and low-

income countries have been treated by informal recycling sectors instead of formal facilities

(Ikhlayel, 2018). Recycling practices in informal sectors in such developing countries may

create a multitude of problems in the context of governance. In many low-income countries,

informal sectors established their businesses before public authorities implemented E-waste

management protocols. According to ESDO (2010), a formal recycling sector did not exist in

Bangladesh until 2010. Existing businesses involved in E-waste management may hinder the

establishment of newly launched public recycling facilities through competition. If legal

frameworks for managing E-waste recycling are established—for example, inventories and

financial mechanisms—informal recyclers could over-report the amounts of E-waste they

have treated to receive extra subsidies from the government (Kojima et al., 2009). Achieving

７
balance between formal and existing informal sectors requires a comprehensive consideration

of the country's business environment.

Furthermore, many harmful recycling practices carried out by informal recycling

sectors may harm the health of workers—for example, manual separation or dissolution using

strong acidic chemicals without a proper level of personal protective equipment. Schnoor

(2012) reported that workers at illegal E-waste recycling sites in Guangdong, China worked

without any gloves or protection while sitting in dust and debris. In Bangladesh, it was

estimated that more than 50,000 children were involved in informal E-waste management,

and around 83% of them suffered from illnesses attributed to the exposure to the toxic

substances; consequently, up to 15 % of them suffered from premature death (ESDO, 2010).

Another study carried out by Pure Earth, a non-profit organization of the US and the Geology

Department of Dhaka University, during 2011-2017, identified 166 lead-contaminated sites

almost all over Bangladesh (Pure Earth, 2019). There was a component of health impact

study. At Kathgora, Savar and Dhaka, the health impact investigating team found presence of

higher level of lead in the blood of 300 people, 90 % of them are children. They are at serious

of health risk (McCartor and Nash, 2019).

2.1.4 Transboundary movement of E-waste

One difficulty in E-waste management in developing countries arises from the nature

of the transboundary movement of the waste. Although a significant fraction of E-waste

originates from the domestic usage of electronic equipment, a large volume of E-waste is also

imported illegally into developing countries in the name of second-hand electrical and

electronic equipment (Osibanjo and Nnorom, 2007). Many developed countries have adopted

the framework of EPR to induce environmentally sound management of E-waste.

８
 The EPR mechanism, however, cannot be adequately operated in developing

countries because the producers are not integrated into the domestic legal framework. Large

volumes of E-waste have been illegally imported to the countries. Golev et al. (2016)

estimated 75–80% of E-waste generated around the whole world was exported to the

developing countries especially the countries in Africa and Asia. Thus, the acquisition of

funding from large companies out of the country that is responsible for E-waste generation

cannot be achieved in developing countries. To tackle such a problem, E-waste legislation in

developing countries should be drafted in accordance with international policies, regulations,

conventions, and initiatives. The details of international initiatives to manage E-waste will be

explained in a later section. Furthermore, upstream reduction of E-waste should be prioritized

through sound practices of the design-for-the-environment approach, which considers the

producers to have an eco-responsibility in contrast to the traditional profit-focused approach

(Herat and Agamuthu, 2012).

2.2 Current status of E-waste management in Asia: India and China

2.2.1 India

Indian E-waste Management Rules are presently based on the EPR principles, and in

the coming next few years the EPR model will be strengthened. Any producers of electrical

or electronic equipment for channelizing E-waste take responsibility to ensure

environmentally sound management of such waste. EPR may comprise of implementing take-

back system or setting up of collection centers or both and having agreed arrangements with

authorized dismantlers or recyclers either individually or collectively through a Producer

Responsibility Organization (PRO) recognized by producers in their Extended Producer

Responsibility - Authorization; A professional organization authorized or financed

９
collectively or individually by producers, which can take the responsibility for collection and

channelization of generated E-waste from the ‘end-of-life’ of their products to ensure

environmentally sound management of such E-waste; India is considered as one of the

regions that receives most of the E-waste export. India established the E-waste Management

Rules, on October 1, 2016, which made EPR mandatory (MOEF, 2016). E-waste

Management Rules in India has been amended in 2018.

E-Parisara is the first E-waste formal recycler in India. It takes in various E-waste

from IT, public and private sectors. It has a success of 99% recycling and 1% left for

scientific disposal. It is India's first E-waste recycler to obtain both ISO 14001:2004 and

OHSAS 1B001:2007 certifications. E-Parisara created jobs for 150 people (direct) and 60

people (indirect). Process of converting a Product Waste into Raw material includes : 1)

Manual Dismantling 2) Hands on Segregation-Magnetic separator 3) Shredding and 4)

Density Separation. E-Parisara adopts the above mentioned techniques, converting E-waste

into raw materials such as metals, plastics, glass and others. Some examples of formal E-

waste recycling plants are shown in Figure 2-1.

１０
 (a) E-waste recycling plant in Bangalore (Cable shredding and separation)

(b) E-waste recycling plant in Bangalore and Chennai (Manual separation)

(c) E-waste recycling plant in Bangalore (Laboratory, stores bin)

Figure 2-1. Formal E-waste recycler in India

E-waste management in India identified that computer equipment account for almost

70% of e-waste, followed by telecommunication equipment phones (12%), electrical

equipment (8%), and medical equipment (7%) with remaining from households. The E-waste

generation in India has been growing at faster rates, with 1.98 million tons generated in 2016

and two million in 2018 at 1.5 kg per inhabitant on average annually. The collection

percentage of the waste by formal recyclers was very low, nearly 80% of E-waste recycling

was carried out by the informal sector, creating environmental pollution and health hazards

(Baidya et al. 2020).

１１
 Informal sector entrepreneurs or enterprises do not pay taxes, have no trading license

and are not included in social welfare or government insurance schemes. They sell these to

the small traders who primarily segregate E-waste and sell it to the bigger traders known as

the wholesalers. They segregate and sort out different types of E-waste and sell them to the

recyclers and/or the dismantlers. In this process, people who dismantle E-waste are

performing work without safety measures as shown in the Figure 2-2.

Figure 2-2. Dismantling E-waste by child in informal sector in India

India's E-waste management system is not formally developed; moreover, it is poorly

defined and unorganized. Figure 2-3 presents the schematic overview of physical and

financial flows of EEE in India, which can be broadly divided into three levels (Wath et al.,

2010; Ghosh et al., 2016). The first level, EEE generation, marks the actual entry of new

electrical and electronic equipment, raw materials, components, assemblies, and sub-

assemblies into the country, either through production/manufacturing by producers and

manufacturers who are located in India, or through its import from foreign countries by

Indian importers. As distributors, retailers, and raw material suppliers are not the real users of

these EEE items and raw materials, they are only considered to be actors in EEE generation

but not in E-waste generation (Manomaivibool, 2009; Baidya et al. 2020).

１２
 The second level, domestic as well as official consumers are the real users of EEE, as

they purchase newly generated EEE from the actors of the first level (EEE generation) in

order to serve their present needs. In the case of personal computers, televisions, etc.,

consumers often discard their old items for the sake of the newest versions, features, and

options to meet their present needs. In India, EEE may find more than one user, as initial

domestic users may resell or give used EEE to their domestic relatives or friends for further

use. Official consumers may also donate their used EEE to poorly funded social institutions

like charitable schools, hostels, orphanages, hospitals, or village societies. It has also been

reported that large amounts of E-waste enter India from foreign countries in the name of

charity without payment of any duties (Wath et al., 2010; Debnath et al., 2016).

The third level, E-waste re-processing, can be further divided into the pre-

reprocessing stage and the reprocessing stage. The actors involved are mostly unorganized. In

the pre-reprocessing stage, collection of E-waste is mostly done by the unorganized sector of

scrap dealers/traders, called “Kabadiwala” in the local language; the Kabadiwala purchase E-

waste from the consumer, along with other recyclable waste or scrap like old newspapers,

books, cardboards, plastics, ferrous-tin material items, and glass bottles, and sell it to

wholesalers or bigger traders through small traders. The wholesalers/traders then segregate

and sort out different types of waste material and ultimately sell it to the recyclers/dismantlers

and disposers for reprocessing.

１３
 Figure 2-3. Existing E-waste trade system flows in India
(Wath et al., 2010; Debnath et al., 2016)

An overall national E-waste management system for India is proposed in Figure 2-4,

and is comprised of a decentralized door-to-door collection mechanism run by small traders

that is both flexible and informal. The proposed system is based in present E-waste scenarios

and current social and economic conditions. At the pre-reprocessing stages of collection and

trading, the proposed system does not disperse any hazardous components from the waste

into the environment; moreover, collecting and pre-processing can be handled efficiently by

the informal sector while also offering numerous job opportunities. Registration for E-waste

collectors/traders would not be mandatory in the proposed E-waste management system for

India (Widmer et al., 2005; Awasthi et al., 2018). Although registration would be encouraged

amongst recyclers, the option to avail the advance recovery fee (ARF) benefit may be

available only to registered E-waste collectors/traders. On other hand, the reprocessing stages

of treatment and recycling involve the dispersion of hazardous materials into the environment;

hence, registration may be made mandatory for recyclers and disposers to limit

environmental impact. It is also proposed that the ARF benefit may be subject to quarterly or

１４
semiannual auditing by third party auditors to ensure compliance and enforcement of set

standards and regulations. Such formal management can also maintain control over potential

malpractice in law enforcement and make the system more transparent.

Figure 2-4. Proposed E-waste management system for India

(Wath et al., 2010; Awasthi et al., 2018)
, tax credit option may be extended to those manufactures/producers/raw material producers who adopted the concept of Eco-design.

, subject to third party audit for getting ARF benefit by the registered/authorized collectors, traders, recyclers, disposers.

, control and coordination by task force. ARF, Advance Recycling Fee (based on the principal of Indian Government Provident Fund Scheme).

, direction of ARF flow.

, direction of material flow.

, registration should be made mandatory (optional for collectors/traders for availing the ARF benefit).

However, there are still a number of issues and challenges in E-waste management.

Followings are some of the challenges and issues (Awasthi and Li, 2017):

a) Actual data of E-waste generation,

b) Tracking and Collection of E-waste from source of E-waste use & generation,

c) Littering of low value or non-recyclable non reusable E-wastes in the

waste dump sites,

１５
 d) Responsibly Effective working of PRO (Producer Responsible Organization),

e) Effective EPR implementation as per rules by the producers,

f) Existence of formal units of E-waste recycling,

g) Health and safety issues of informal recyclers,

h) Adverse Environmental impact of the processes adopted in informal recycling

i) Illegal imports & exports of E-wastes

2.2.2 China

China is currently in the process of creating a Cradle to Grave approach on e-waste

management. Improper management of E-waste, such as manual dismantling and acid

leaching without personal protective equipment, was recognized as a threat to human health

and the environment. To address this threat, China has issued a number of guidelines and

regulations related to e-waste starting in 2006. The E-waste management can be divided into

four phases: informal dismantling, coexistence, preparation of the EPR system, and

implementation of the EPR system (Zeng et al., 2013; Cao et al., 2016).

a) Informal dismantling (1980 ~ 2000)

Environmental and ecological problems have occurred in southern China due to

illegal transboundary movement and informal treatment of E-waste. These problems have

resulted from inadequate recycling networks and technology as well as insufficient legislation

(Li and Zhao, 2010; Yang et al., 2008).

b) Phase on coexistence (2001 ~ 2008)

１６
 To address the pollution caused by E-waste and to establish a recycling system and

management method for E-waste, the National Development and Reform Commission

(NCRC)conducted a pilot project in Qingdao City, Zhejiang Province, Beijing City, and

Tianjin City. Additionally, four official national enterprises were founded: Qingdao Haier

Group Company, Hangzhou Dadi Environmental Protection Company, China Huaxing Group

Company, and Tianjin Datong Copper Industry Company (He et al., 2006).

During this time period, several draft regulations on E-waste were prepared in China,

and adequate recycling processes for E-waste were developed in the laboratory and tested in

the field. Thus, this period represented the coexistence of informal treatment and national

enterprises.

c) Phase on preparation of EPR system (2009 ~ 2012)

In China, new legislation was prepared and included E-waste and RoHS regulations

within which the Chinese government was given oversight of producers, distributors, and

recyclers. Since 2009, the ‘Old for New’ measure has been used to transition to the EPR

system in accordance with WEEE and RoHS regulations. The ‘Old for New’ measure

included subsidies to stakeholders related to E-waste (Zeng et al., 2013; Zhou and Xu, 2012).

Consumers who sold E-waste were able to receive subsidies when purchasing new

products, and a maximum subsidy for each type of electronic waste was stipulated to induce

the separate discharge of E-waste from MSW by the consumer. Collection companies were

able to receive subsidies depending on transportation distance, which were subsequently used

to establish an E-waste collection system in China. In addition, E-waste disassembly and

treatment companies were provided with subsidies for each E-waste type to facilitate the

development of treatment technology and establishment of facilities (MOFCOM, 2020).

１７
 d) Phase on implementation of EPR system (2012 ~ )

Legislation on the EPR system was implemented in July 2012. This legislation

consisted of general rules, tax administration, subsidy utilization, supervision, liability, and

supplemental rules (Government of China, 2020). The legislation applied to domestic

producers and importers of electrical and electronic equipment who are taxed by the Chinese

government (State Administration of Taxation and Customs). These taxes are mainly used as

subsidies for E-waste recycling.

The flow of taxes by the EPR system in China is shown in Figure 2-5 (Cao et al.,

2016). In conjunction with legislation concerning the EPR system, an Administrative

Measure on E-waste Recycling Enterprises Permit was introduced by the government.

Experts from the Ministry of Environmental Protection (MEP), the Ministry of Finance

(MOF), the Ministry of Industry and Information Technology (MIIT), and the National

Development and Reform Commission (NDRC) conducted field inspections of recyclers

applying for subsidies on recycling of E-waste. As a result of these measures, 91 formal E-

waste recyclers were given subsidies in 2014 and recycling capacity reached 118 million

units per year (Cao et al., 2016; CHEARI, 2013).

Figure 2-5. The flow of taxes by EPR system in China (Cao et al., 2016)

１８
 2.3 Transboundary movement: International legal frameworks applicable to

E-waste management (focused on Basel Convention)

Awakening environmental awareness and corresponding tightening of environmental

regulations in the industrialized world in the 1970s and 1980s had led to increasing public

resistance to the disposal of hazardous wastes and to an escalation of disposal costs. This in

turn led some operators to seek cheap disposal options for hazardous wastes in Eastern

Europe and the developing world, where environmental awareness was much less developed

and regulations and enforcement mechanisms were lacking. It was against this background

that the Basel Convention was negotiated in the late 1980s, and its thrust at the time of its

adoption was to combat the “toxic trade”, as it was termed.

The Basel Convention on the Control of Transboundary Movements of Hazardous

Wastes and their Disposal was adopted on 22 March 1989 by the Conference of

Plenipotentiaries in Basel, Switzerland, in response to a public outcry following the discovery,

in the 1980s, in Africa and other parts of the developing world of deposits of toxic wastes

imported from abroad. The Convention entered into force in 1992.

Since adoption of the Basel Convention, the third of the Conference of the Parties in

1995 adopted the “Ban Amendment”, introducing a new preamble paragraph, a new Article

4A and a new Annex VII. The Ban Amendment provides for the prohibition of exports of all

hazardous wastes covered by the Convention that are intended for final disposal, reuse,

recycling and recovery from countries listed in annex VII to the Convention (Parties and

other States which are members of the OECD, EC, Liechtenstein) to all other countries. The

Ban Amendment entered into force on 5 December 2019 (UNEP 2020).

１９
 2.3.1 Objective and provisions of Basel Convention

Extended Producer Responsibility (EPR) policy has been widely employed in many

countries, especially in EU, since 1990s. One of the major products that are commonly

managed by EPR is electronics. EPR involves producers (manufacturers, suppliers, retailers,

importers) taking extended responsibility for their products so that there is a direct incentive

for the design and manufacturing of environmentally conscious products that can be easily

recycled, and do not present significant environmental impacts upon disposal.

The overarching objective of the Basel Convention is to protect human health and the

environment against the adverse effects of hazardous wastes. Its scope of application covers a

wide range of wastes defined as “hazardous wastes” based on their origin and/or composition

and their characteristics, as well as two types of wastes defined as “other wastes” - household

waste and incinerator ash.

The provisions of the Convention center around the following principal aims:

- the reduction of hazardous waste generation and the promotion of environmentally

sound management of hazardous wastes, wherever the place of disposal;
- the restriction of transboundary movements of hazardous wastes except where it is
perceived to be in accordance with the principles of environmentally sound
management; and
- a regulatory system applying to cases where transboundary movements are
permissible.

The first aim is addressed through a number of general provisions requiring States to

observe the fundamental principles of environmentally sound waste management (article 4).

A number of prohibitions are designed to attain the second aim: hazardous wastes may not be

exported to Antarctica, to a State not party to the Basel Convention, or to a party having

banned the import of hazardous wastes (article 4). Parties may, however, enter into bilateral

２０
or multilateral agreements on hazardous waste management with other parties or with non-

parties, provided that such agreements are “no less environmentally sound” than the Basel

Convention (article 11). In all cases where transboundary movement is not, in principle,

prohibited, it may take place only if it represents an environmentally sound solution, if the

principles of environmentally sound management and non-discrimination are observed and if

it is carried out in accordance with the Convention’s regulatory system.

The regulatory system is the cornerstone of the Basel Convention as originally

adopted. Based on the concept of prior informed consent, it requires that, before an export

may take place, the authorities of the State of export notify the authorities of the prospective

States of import and transit, providing them with detailed information on the intended

movement. The movement may only proceed if and when all States concerned have given

their written consent (articles 6 and 7). The Basel Convention also provides for cooperation

between parties, ranging from exchange of information on issues relevant to the

implementation of the Convention to technical assistance, particularly to developing

countries (articles 10 and 13). The Secretariat is required to facilitate and support this

cooperation, acting as a clearing-house (article 16). In the event of a transboundary

movement of hazardous wastes having been carried out illegally, i.e. in contravention of the

provisions of articles 6 and 7, or cannot be completed as foreseen, the Convention attributes

responsibility to one or more of the States involved, and imposes the duty to ensure safe

disposal, either by re-import into the State of generation or otherwise (articles 8 and 9).

The Convention also provides for the establishment of regional or sub-regional

centers for training and technology transfers regarding the management of hazardous wastes

and other wastes and the minimization of their generation to cater to the specific needs of

２１
different regions and sub-regions (article 14). Fourteen such centers have been established.

They carry out training and capacity building activities in the regions.

2.3.2 The scope of hazardous waste of Basel Convention

The Basel Convention stipulates the prevention of environmental pollution caused by

hazardous wastes by minimizing the trade of hazardous wastes and establishing a cooperative

system between import and export countries, and consists of 29 articles and 9 annexes.

Article 1 of the text refers to the scope of the Convention, and the scope of the Convention

defines control of transboundary movement of waste included in Annex I with hazardous

characteristics of Annex III. The 59 kinds of wastes adopted by the 4th COP of the Parties

shown in Annex VII, and other wastes shown in Annex II are applicable, and the scope of

hazardous wastes regulated by the Basel Convention is shown in Figure 2-8.

Figure 2-6. Wastes subject to control in the Basel Convention

２２
 2.3.3 Classification E-waste in Basel Convention

E-waste is categorized as hazardous waste due to the presence of toxic materials such

as mercury, lead and brominated flame retardants are considered as hazardous waste

according to the Basel Convention. E-waste may also contain precious metals such as gold,

copper and nickel and rare materials of strategic value such as indium and palladium. These

precious and heavy metals could be recovered, recycled and used as valuable source of

secondary raw materials. It has been documented that E-waste is shipped to developing

countries where it is often not managed in an environmentally sound manner, thus posing a

serious threat to both human health and the environment.

Since 2002, the Basel Convention has dealt with issues on a variety of topics of

E-waste including Environmentally Sound Management (ESM), prevention of illegal traffic

of E-waste to developing countries. In the Basel Convention, most E-waste devices are

classified as hazardous waste, and the principle is to prohibit the transboundary movement of

hazardous waste. When transboundary movement of E-waste as non-hazardous waste, official

inspection or supporting documents must be attached.

E-waste under the Basel Convention is waste containing hazardous substance by Y-

code such as Y31 (lead and its compounds), and the waste containing metal components of

A1 and A2 in the A-list. Also, wastes classified as non-hazardous wastes not included in the

Y-code and A-list are B1110 (non-hazardous electrical and electronic assembly) (See Table 2-

1) (Basel Convention, 2017).

２３
 Table 2-1. Examples on classification of E-waste under the Basel Convention
Type of E-waste Y-code(Annex I) List A or B (Annex VIII, IX)
Various (e.g. Y20,
E-waste, unsorted A1180
Y27,Y31, Y45)
Lead-containing glass from cathode
Y31 A1180, A2010
ray tubes (CRTs) and imaging lenses
Nickel-cadmium batteries and
Y26, Y29 A1170
batteries containing mercury
Selenium drums Y25 A1020
Various (e.g. Y20,
Printed circuit boards A1020, A1180
Y27,Y31, Y45)
PCB- or PCT-containing equipment Y10 A1180, A3180
Plastic components containing
Y45, Y27 A3180
brominated flame retardants
Mercury-containing fluorescent
tubes
and backlight lamps from liquid Y29 A1030
crystal displays (LCD),Fluorescent
lamps
Other mercury-containing
A1010, A1030,
components, such as mercury Y29
A1180
switches, contacts and thermometers
Components containing asbestos,
Y36 A2050
such as cooking stoves and heaters
Non-hazardous waste electrical and
Not applicable B1110
electronic assemblies

2.3.4 E-waste management under Basel Convention

E-waste is a serious health problem affecting millions of young children, adolescents,

future mothers to-be across the world. These are people who work in dangerous conditions to

retrieve precious metals to earn money to support their families. This work exposes them to

dangerous chemicals, heavy metals, toxic air. E-waste pollutes their communities, their

homes, their schools, their soil, their food, and the air they breathe. We urgently need to have

E-waste very clearly identified as a health problem. As the health agency of the United

２４
Nations, WHO’s duty is to communicate the evidence, the information, the tools we have

available to address this emerging health hazard.

The Basel Convention recommends the application of Extended Producer

Responsibility (EPR) for the management of various wastes, including E-waste by

Environmentally Sound Management (ESM) approach (Basel Convention, 2018; Basel

Convention, 2020c). In the Basel Convention, the definition of EPR is define: Environmental

policy approach in which a producer’s responsibility for a product is extended to the waste

stage of that product’s life-cycle. In practice, EPR involves producers taking responsibility

for the management of products after becoming waste, including: collection; pre-treatment,

e.g. sorting, dismantling or de-pollution; (preparation for) reuse; recovery (including

recycling and energy recovery) or final disposal. EPR systems can allow producers to

exercise their responsibility either by providing the financial resources required and/or by

taking over the operational aspects of the process from municipalities. They assume the

responsibility voluntarily or mandatorily; EPR systems can be implemented individually or

collectively.

The EPR scheme is any system established by one or several producers to implement

the EPR principle. It can be an individual system (or individual compliance system) where a

producer organizes its own system, or a collective system (collective compliance system)

where several producers decide to collaborate and thus fulfil their responsibility in a

collective way through a specific organization (e.g., Producer Responsibility Organization).

The principles of EPR system include enforcement, social dimensions, transparency,

international alignment (see Table 2-3), and the detail key elements include: definition of

product, registration of producer, mandatory or voluntary EPR systems, individual or

collective EPR systems, responsibilities, leakage, target, costs and financing, fees,

２５
transparency, Monitoring and surveillance, and others.

The EPR system of this concept can also be found in OECD's 'Extended Producer

Responsibility Updated Guidance for Efficient Waste Management' and StEP's Developing

Legislative Principles for E-waste policy in developing and emerging countries' (OECD,

2016; StEP, 2018).

Table 2-2. Principles and elements of EPR system

Element Description
- Legislation should include clear procedures for registration of producers,
Enforcement quantities put on the market and reporting requirements.
- Legislation should provide the basis for procedures on licensing and auditing of
dismantler and recycler operations.
- Sanctions and penalties for non-compliance should be clear to actors,
proportionate to the offence and enforceable by government agencies
- Legislation should foresee the establishment of an E-waste Advisory Council.
Social - Incentives and options for informal stakeholders to become part of the EPR-
dimensions based system, through organization and gradual formalization
- Legislation should stimulate EEE users to utilize licensed collection and
recycling facilities
- Legislation should ensure that income collected within the EPR-based system
Transparency is appropriately used for the allocated purpose of collection and recycling of E-
waste and not for other purposes
- Legislation should ensure that the flow of financial obligations and operational
performance should be auditable by a neutral 3rd party that has no direct
benefit
International - Definitions, standards related to treatment operations, and rules for
Alignment transboundary shipments should be as far as possible be aligned with
international guidelines and/ or conventions.

２６
 2.3.5 Control of transboundary movement of waste in Bangladesh

In Bangladesh, in order to control hazardous waste, the Hazardous Waste and Ship

Breaking Waste Management Rules 2011 under the Environment Conservation Act (1995)

was prepared for implementation of the Basel Convention. The wastes in question are listed

in schedule 1, 2, 3 of Hazardous Waste and Ship Breaking Waste Management Rules 2011 in

line with the lists of wastes contained in Basel Convention. The procedures are same that is

covered under the Basel Convention. According to Hazardous Waste and Ship Breaking

Waste Management Rules 2011, it would obtain clearance from the Director General (DG),

Department of Environment (DOE) prior to shipment for export. As Bangladesh has no

facility/do not have the skill to dispose of Hazardous waste (final disposal), the provision of

exemptions is in place of special requirements. However, official data on the transboundary

movement of hazardous wastes and other wastes that require reporting in the Basel

Convention is not available in Bangladesh (Basel Convention, 2020d).

The classification of E-waste in the Basel Convention includes fluorescent lamps.

Fluorescent lamps are divided into Compacted Fluorescent Lamps (CFL) and Fluorescent

Tube Lamps (FTL), and CFLs and FTLs contain toxic mercury with glass and other metal

substances. (Rhee et al., 2014; Rhee, 2017). Mercury is a serious threat to human health. If

the CFLs and FTLs are disposed improperly, crushed or broken, it may release mercury into

the environment (Park and Rhee, 2016; Choi and Rhee, 2017). Mercury can also affect

human food chain. There are high damage costs associated with mercury contamination, so

proper initiatives are required to mitigate the negative impact and health hazards of mercury

release into the environment. Therefore, for environmentally sound management of CFLs and

FTLs, national management plan of mercury containing lighting equipment was proposed for

Bangladesh.

２７
 Bangladesh's national plan for lighting equipment containing mercury includes

fluorescent lamps such as CFLs and FTLs, which are mercury-added products under the

Minamata Convention. When these fluorescent lamps are discarded, they are considered

mercury waste classified under the Minamata Convention.

In the Minamata Convention, mercury waste is classified into categories A to C,

which are as follows.

• Category A waste: Consisting of mercury or mercury compounds

• Category B waste: Containing mercury or mercury compounds
• Category C waste: Contaminated with mercury or mercury compounds

Mercury waste thresholds were discussed in third meeting of the Conference of the

Parties to the Minamata Convention to specify these three categories of mercury waste. As a

result, Category A and B waste specified the types of waste listing, and discussion on

Category C waste is still underway.

In particular, CFLs and FTLs are included in Category B waste. In addition to CFLs

and FTLs, the lamps containing mercury included in Category B waste include Cold Cathode

Fluorescent Lamps (CCFL) and External Electrode Fluorescent Lamp (EEFL). CCFLs and

EEFLs are parts of an LCD (liquid crystal display) device. Therefore, it is necessary to

consider including CCFLs and EEFLs along with CFLs and FTLs in lamp management in

Bangladesh. Since these lamps containing mercury are also classified as E-waste, they must

be disposed of at an authorized E-waste recycling facility for safe disposal of lamps

containing mercury.

The Montreal Protocol also needs to be considered when managing E-waste in

Bangladesh. The Montreal Protocol eliminated the use of chlorofluorocarbons (CFCs) and

２８
hydrochlorofluorocarbons (HCFCs). Products to which these refrigerants are applied are

listed in Annex D under the Montreal Protocol, and include refrigerators, freezers and

dehumidifiers that can be classified as E-waste. Accordingly, the use of hydrofluorocarbons

(HFCs) as an alternative refrigerant for CFCs and HCFCs has increased, but the recent Kigali

amendment has set the goal of gradual reduction of HFCs. Article 9 of the Montreal Protocol

requires the development and exchange of information on technologies that improve the

containment, recovery, recycling or destruction of refrigerants such as CFCs, HCFCs and

HFCs. It also seeks to develop possible alternatives to products containing these substances.

Therefore, for E-waste such as refrigerators that contain refrigerant substances that are

controlled substances under the Montreal Protocol, it is necessary to consider a method to

recover and destroy the refrigerant at an authorized E-waste recycling facility.

２９
3 The current situation on managing E-waste in Bangladesh

To materialize the blueprint of Digital Bangladesh stated in Bangladesh Vision 2021

(Center for Policy Dialogue, 2007), the manifesto of the Awami League, the Bangladesh

government made great efforts to transform the industrial scheme of the nation. Information

and communications technology (ICT) is at the core of the vision, thus tremendous

investment was carried out there and the nation's endeavors seem successful as evidenced by

fast economic growth. In a recent decade, the average annual economic growth rate of

Bangladesh was 7 % and marked 8.2 % in 2019 (World Bank, 2020). Bangladesh has not

only crossed the threshold of Lower Middle Income (LMI) countries in 2015, but also met the

criteria for graduation out of least developed countries status. Bangladesh Government also

adopted Vision 2041 (General Economic Division, 2020) with some specific objectives such

as eliminating extreme poverty; reach Upper Middle-income Country (UMIC) status by 2030,

and High Income Country (HIC) status by 2041. Bangladesh is expected to experience an

accelerated pace of transformational change in most of the sectors over the next fifty years.

However, fast industrialization has two sides of the coin, as experienced by many

countries including South Korea. The unsound practice of expanded industry and exploitation

of resources may harm the surrounding environment. The generation of huge amounts of E-

waste is crucial issues in Bangladesh aroused from the evolution of the industries regarding

ICT sectors. Illegal imports of E-waste in the informal recycling sector to monetize can also

be a challenging problems for Bangladesh to maintain their environment and protect the

occupational health and safety of laborers in the sector.

It is important to correctly diagnose the current situation of the E-waste problems in

Bangladesh to prepare and plan an effective solution. Therefore, a detailed survey on

accessible literature and legal documents was carefully carried out to find critical problems,

３０
research gaps, and implications for sustainable waste management in Bangladesh. In this

chapter, the current status of the legal framework on E-waste management and E-waste

generation trends were reviewed. Some key challenges on E-waste management were

highlighted, including environmental pollution, limited regulatory measures, lack of

partnerships between stakeholders, insufficient awareness, and financial burden. In a closing

remark of this section, strength/weakness/opportunity/threat (SWOT) analysis was performed

and several strategies for E-waste management were drawn.

3.1 Evaluation of the current regulatory framework on managing E-waste in

Bangladesh

3.1.1 Outline of relevant laws

The evolution of legislation regarding environmental conservation in Bangladesh is

outlined in Figure 3-1. After Bangladesh gained its independence in 1971, the first legislative

step regarding environmental protection began with the Environmental Pollution Control

Ordinance of 1977. In the ordinance, “waste” was defined as sanitary sewage, industrial

discharges, and all other liquid, gaseous, solid, radioactive and other substances which may

pollute or tend to pollute environment. The ordinance stipulated the role of the Environmental

Pollution Control Board and empowered them to control stakeholders for environmental

protection.

３１
 Figure 3-1. A brief history of the development of environmental law in Bangladesh

With supports from the National Environmental Policy of 1992 (MOEF, 1992) and

the Environmental Conservation Act 1995(ECA) (MOEF, 1995b) was enacted to protect and

sustainably manage the environment (Clemett, 2006). The Environmental Conservation Rules

1997 (ECR) was later enacted to support the Act (MOEF,1997). Although the Act did not

contain specific information concerning E-waste management, the Rules in the teeth of Act

included several articles that can be cited in the future to draft legislation on E-waste

management. These articles such as Clause 3 and 4 of the Act are related to the powers and

functions of the Department of Environment (specifically, the Director-General), such as ;1)

issuing directions to the interested individuals or parties regarding the environmentally sound

use ,storage ,transportation ,import and export of a hazardous substances or its components; 2)

collecting and publishing information about environmental pollution; 3) making regulations

or rules such as standard of pollution, and 4) rendering other authorities to render necessary

assistance.

Under the Environment Conservation Rules 1997, an industrial unit or project should

apply for an Environmental Clearance Certificate before being launched. Industrial units or

projects are classified into four categories (GREEN, ORANGE-A, ORANGE-B, and RED)

３２
depending on their potential environmental impact; categories are often delineated based on

the nature of the unit or project. Industrial sectors labeled GREEN do not require many

complicated documents; conversely, those labeled RED (Highly Polluting) requires numerous

complicated documents including a report on the feasibility of the industrial unit or project, a

report on the Initial Environmental Examination, and terms of reference for the

Environmental Impact Assessment. In the case of the E-waste management sector, certificate

categories for collection or recycling of E-waste are not specifically assigned and are difficult

to define. The category for manufacturing new electronic devices varies depending on the

items. The proper categorization of E-waste management activities for the Environmental

Clearance Certificate should be determined in a future amendment of this rule or formulate a

Statutory Regulatory Order, so-called S.R.O.

The Environment Court Act 2010 was enacted to establish the nation’s Environment

Court and provide direction for incidental matters (MOEF,2000). Pursuant to this act, the

government of Bangladesh can enforce actions legally required for environmental protection

not only in an administrative manner but also formal judicial basis (or both). The Act states

the procedures and powers of the Environmental Court.

Until now, there has not been a law directly linked to E-waste management. The

Environment and Social Development Organization (ESDO) in 2010 and Islam et al. (2016)

stated that the Medical Waste (Management and Processing) Rules of 2008 referred to E-

waste as one type of hazardous medical waste (MOEF,2008),but our review did not find any

legislative clause or item associated with E-waste in the 2008 Rules. The National 3R

(Reduce, Reuse, and Recycle) strategy contained regulations on E-waste management, but the

strategy is a type of policy regime, not a lawful document (Karim et al., 2014).

３３
 According to a review on the legal framework of Bangladesh by Masud et al. (2019),

the draft Solid Waste Management Rules 2019 was prepared and currently at the final phase.

It is recommended that the design of new plans or policies for E-waste management should

be in an accordance with the draft rules as well as the relevant law already legislated. The

possibility of overlapping articles and the relationship between each rule should be

thoroughly inspected before official documentation.

3.1.2 Hazardous Waste (E-waste) Management Rules (Draft) in 2019

The Hazardous Waste (E-Waste) Management Rules (Draft) 2019 is a law focusing

on proper management of E-waste (MOEF, 2019). Although the title of the Rules includes

"hazardous waste,” the law focuses only on E-waste. The main aim of this rule is to regulate

the management of E-waste in an environmentally sound manner under the upper level of the

law, the Environmental Conservation Act. The rules present the scope and responsibilities of

stakeholders for achieving EPR, collection targets, registration of E-waste management,

restricted use of toxic substances in electronics, and the prohibition on imports of used

electrical and electronic products. This rules will be enacted soon.

Under the law, "E-waste” is defined as electric/electronic products deemed to have

lost its economic life or has lost its usefulness or utility to the user or which has been left out

in the manufacturing process or discarded for unnecessary consideration. The list of specific

items regarded as E-waste is included in Schedule 1 of the law (Table 3-1). Briefly, the list

includes 25 types of the home appliances, 10 items of monitoring and control instruments, 18

pieces of medical equipment, 2 automatic machines, 13 pieces of information technology and

telecommunication equipment.

３４
Table 3-1. The specific items mentioned in Schedule 1 of Hazardous Waste (E-waste)

Management Rules (Draft) of 2019:

Class/Catagory Products / Equipment

Household (a) Compact Fluorescent Lamp or Mercury Lamp
appliance (b) Led Capacitor / Battery / Lithium-Ion Battery
(c) Thermal cut-off of cadmium and its compounds
(d) Refrigerator
(e) Washing machine
(f) Dish washer
(g) Microwave oven
(h) Other electrical/electronic appliance used for cooking and
processing of food
(i) Electric heating appliance
(j) Vacuum cleaner
(k) Iron and similar other appliance
(l) Toaster
(m) Battery, Lamp
(n) Grinder
(o) Coffee maker
(p) Fryer
(q) Television (CRT, LCD, LED etc.)
(s) DVD Player/VCR/VCP
(t) Video camera
(u) Video recorder
(v) Digital camera
(w) Radio/Audio amplifier
(x) Electrical/electronic Musical instrument
(y) Air conditioner
(z) Electric-powered water filters/purifiers, water heaters/geysers,
and any other household products
Monitoring and (a) Smoke detector
control (b) Control panel in industrial installation/power plant
instruments (c) Heating regulator
(d) Thermostat
(e) Weighing devices used at home or in the laboratory
(f) Fire Extinguisher
(g) Non-radioactive testing and control equipment or industrial
power station equipment (control equipment)
(h) Central Air Conditioner / Chiller
(i) Different types of measuring and various coordinating
instruments used in domestic work and laboratory
(j) Engineering / Environmental Survey Instruments
(k) Arsenic Measurement Instruments

３５
 Medical (a) Microscope
Equipment (b) Respiration Monitors
(c) Glucose Monitors
(d) Physical Therapy Devices
(e) Laboratory Measurement Equipment (Thermometer, pH
meter, Conductometer, Measuring Instrument, Titratable
Acidity Mini Titrator, Refractive Index, Measurement of
Liquids, etc.)
(f) Defibrillators
(g) MRI Equipment
(h) Diagnostic Imaging Equipment
(i) Biomedical/Pathological Testing Devices
(j) Urinalysis Equipment
(k) Endoscopy Equipment
(l) Hematology Equipment
(m) Vital Sign Monitors
(n) Ultrasound Equipment
(o) Computed Tomography (CT) Equipment
(p) X-Ray machine
(q) Other e-equipment used in Hospital and also in Diagnosis
center
(r) Research-based Lab Equipment etc.

Automatic (a) Automatic dispenser for beverage/drink

Machine (b) Automated Teller Machine

Information (a) Central data processing: mainframe computer, mini

technology and computer,
telecommunication personal computer
equipment (b) Computer Monitor
(c) Laptop
(d) Notebook/note pad or similar device
(e) Printer
(f) Photocopier
(g) Scanner
(h) Floppy
(i) Calculator
(j) Facsimile/Fax
(k) Cellular telephone/mobile phone
(l) land phone/Gescordless phone
(m) Information Technology and Telecommunication related
other products and equipment for the collection/storage of voice,
information/picture, processing, presentation or communication
of information, such as sound, image, data etc. By electronic,
microwave and optical media )

３６
 The law stipulates the responsibilities of stakeholders involved in E-waste

management to stimulate the EPR framework. Table 3-2 summarizes the roles and

responsibilities of stakeholders in E-waste management as presented in the rules. The

producer or assembler has the obligations of collecting E-waste and facilitating reuse. To

achieve these goals, producers/assemblers have to establish private or public collection

centers using private investments or public-private partnerships. The seller is responsible for

the safe collection and transportation of E-waste to the collection center. People who take

charge of refurbishing E-waste must collect E-waste generated during the repair of

electric/electronic products and send it to the collection center. The collection center is

responsible for safe E-waste collection, storage, and transportation. Individual or group

consumers should return E-waste to the seller or collection center. The importer must import

e-waste which is not harmful to the environment or public health. The recycler has a role in

managing hazardous materials released from E-waste recycling; safely storing and

transporting E-waste; and informing workers of the harmful aspects of E-waste. Government

institutions including the Department of Environment, City Corporations, and other local

government bodies (municipalities) have the power and responsibility in supervising the

activities related to E-waste collection, recycling, reuse and demolition.

３７
 Table 3-2. Roles and responsibilities of stakeholders in E-waste management Rules

Stakeholders Role and responsibility

Producers/assemblers - Collecting E-waste and facilitating reuse
- Establishing a private or public collection center by private
investment or public-private partnerships
Sellers - Safely collecting E-waste and sending it to collection centers
Reprocessors - Collecting E-waste generated during repair of electric/electronic
products and sending it to collection centers
Collection centers - Safely collecting, storing, and transporting e-waste
Private/group - Returning E-waste to sellers, or collection centers
consumers
Importers - Importing E-waste that is not harmful to the environment or public
health
Recyclers - Managing hazardous materials released from E-waste recycling
- Safely storing and transporting e-waste
- Promoting the education of workers in recognizing the harmful
aspects of e-waste
Government - Supervising the activities related to E-waste collection, recycling,
Institutions and demolition
(Department of - Department of Environment shall raise awareness among the
Environment, city people
corporation, local about the delivery of E-waste to the collection center
government) - City Corporation and municipalities shall mark a specific
designated a place for the disposal of E-waste

The rules present the targets for E-waste collection by manufacturers, assemblers,

and large importers in Schedule-2. Table 3-3 shows the collection target rates of E-waste by

producers. No recycling target rates are stated in the rules, however.

３８
 Table 3-3. Target rates for E-waste collection by manufacturers, assemblers, and large

importers in Schedule-2 in E-waste rules:

Serial Year Targets for E-waste collection

No (Number / weight)
1. 1st year of implementation of acts Collect 10% of E-waste generated from
the described plan
2. In the 2nd year of implementation of Collect 20% of E-waste generated from
the acts the described plan
3. In the 3rd year of implementation of Collect 30% of E-waste generated from
the acts the described plan
4. In the 4th year of implementation of Collect 40% of E-waste generated from
the acts the described plan
5. Running from the 5th year of Collect 50% of E-waste generated from
implementation of the acts the described plan

The rules also regulated the import of old or used electrical and electronic products

and the export of E-waste. No old or used electrical and electronic products may be imported

or donated, or otherwise accepted. However, the rules stated that those products may be

imported or accepted for use in research and educational institutions without the objections of

the Department. In the case of export, If the necessary arrangements for recycling or reuse of

E-waste are not made in the country, no E-waste will be exported abroad without the

clearance of the Department of Environment.

The basic structure of the law may stem from the E-waste (Management) Rules 2018

in India. Responsibility allocation and design of the target collection rate of E-waste are

similar to the articles in Indian law (Yet, the articles in Indian law are more detailed and

specific). Before the enactment of the new E-waste management rules, it should be

remembered that the Indian laws regarding E-waste management experienced many revisions

３９
to precisely reflect the local situation. The legal framework on E-waste management in India

begun from "E-Waste Handling and Management Rules (2011)” and significantly revised to

"E-Waste (Management) Rules (2016)” based on the spirit of the circular economy. Later, the

law was further amended in 2018. The changes of the Indian law imply the difficulty of

setting a legal framework on E-waste management at once, thus, many revisions will be

necessary to accomplish the target of the law. The situation may be similar in Bangladesh

especially because the two countries have some similarity in social and behavioral patterns,

even the foundation of Bangladesh was deeply associated with their close neighboring

country, India.

3.2 Previous studies: Baseline situation of E-waste generation in Bangladesh

3.2.1 E-waste generation predicted from previous studies

The absence of a countrywide inventory for E-waste is a crucial information gap to

fill for designing and implementing relevant policies—for example, setting target rates of

collection and recycling. Many researchers have estimated the amount of E-waste generated

in Bangladesh to diagnose the country's current situation and support the decision-making of

authorities and practitioners. These estimations are mainly based on the sales-lifespan

approach, which assumes the electric/electronic products turn into E-waste after they are no

longer usable. The formula below shows the mathematical expression of the estimation:

E = ∑ni=1 Mi Ni ⁄Li (1)

where E stands for the yearly amount of E-waste generated (million metric tons/year), M is

the mass of the product, N is the number of products, and L is the lifespan of the products

in the year; the summation is indexed by product category, i.

４０
 As noted above, the lack of an E-waste inventory has resulted in difficulty in

obtaining accurate values for Equation 1. Therefore, many researchers have surveyed

recycling centers or residents in Bangladesh to inquire about information regarding

consumption patterns and lifespans of electric/electronic products. Because target categories

of E-waste and responses to the surveys varied from study to study, existing predictions of E-

waste generation have a very wide range and pose a large degree of uncertainty.

Table 3-4 describes the estimated generation of E-waste in Bangladesh from several

researchers. It appears that the results of ESDO (2012), ESDO (2014), and Masud et al. (2019)

greatly overestimated the E-waste generation compared to the ranges of other studies. Their

values for per capita E-waste generation are comparable to those for advanced countries

having a credible inventory of E-waste and legislation regarding E-waste management—for

example, Hong Kong (19 kg/capita/year), Italy (18.9 kg/capita/year), and Japan (16.9

kg/capita-year) (Balde et al., 2017). The value estimated by ESDO (2014) even exceeds the

value of the country ranked first in E-waste generation, Norway, which has a generation of

28.5 kg/capita/year. Therefore, it appears that the estimations produced in other studies, with

values less than 2.0 kg/capita/year, are more credible.

４１
 Table 3-4. Estimated generation of E-waste in Bangladesh
Reference Year Generation E-waste category Remarks
(Selected item)
million kg/capita/year
ton/year

ESDO (2012) 2011- 2.7 16.7 TVs, computers, - Includes illegally

2012 mobile phones, CFL imported e-waste
bulbs, mercury bulbs, - Information
thermometers, other collected through
medical and dental questionnaires/ surveys
waste, ship breaking
yards
ESDO (2014) 2013- 10.1 62.5 TVs, computers, - Includes illegally
2014 mobile phones, CFL imported e-waste
bulbs, mercury bulbs, - Information collected
thermometers, other through questionnaires/
medical and dental surveys
wastes, household - The questionnaire
electrical appliances included questions
& switches, ship regarding the lifespans
breaking yards and average number of
electrical equipment per
household
Yousuf and Reza 2010 0.018 0.1 Computers, mobile - Investigated in
(2011) phones Dhaka City
- The amount of
generation is the
average value of 2
methods

Alam et al. 2012 0.014 0.1 TVs, mobile phones - Investigated in

(2013) Dhaka City
- Information
collected through
questionnaires/
surveys

Baldé et al. 2016 0.142 0.9 Temperature - Applied the sales-

(2017) exchange equipment, lifespan model
screens, monitors,
lamps
CERM (2019) 2018 0.40 1.9 TVs, air conditioners, - Study based on E-waste
computers, mobile samples collected from
phones, IT different locations
equipment, bulbs, - Does not include E-
refrigerators, fans waste produced through
ship breaking activities

Mott 2018 0.36 1.9 Mobile phones, TVs, - Applied the sales-
Macdonald(2018) computers, lifespan model
refrigerators, bulbs, - Information collected
telecommunications through questionnaires/
equipment, washing surveys; some hidden
machines, air gaps were
conditioners, printers, supplemented by
medical equipment international data

４２
 Masud et al. - 2.8 17.3 Electric charged - There is no detailed
(2019) vehicles, TVs, explanation of methods
computers, mobile to estimate the amount
phones, CFL bulbs, of E-waste generated in
mercury bulbs, the manuscript.
thermometers, other
medical and dental
waste

ESDO incorporated illegal E-waste import and ship breaking yards into E-waste

generation amounts; this is likely the principal contributor for the overestimation, given the

fact that the ship breaking yards counted for around 88 % (8.86 million tons) of total E-waste

generation in their study in 2014. The need to consider ship breaking yards in E-waste

management is not clear, and ship breaking yards are not included in the current E-waste

legislation in Bangladesh. Also, ESDO accounted for illegal imports of E-waste in calculating

domestic E-waste generation, which is not an accurate portrayal of domestic E-waste. On the

other hand, their large estimation implies that a full E-waste inventory is needed, separating

E-waste domestic generation from illegal import from other countries.

The estimations by Yousuf and Reza (2011) and Alam et al. (2013) seem to

underestimate the E-waste generation in Bangladesh, as their scopes were limited to Dhaka

City and the investigated items are restricted to small fractions of total E-waste categories.

Balde et al. (2017) estimated E-waste generation for 177 countries using the sales-lifespan

model; and the lowest value for per capita E-waste generation in 2017 was 0.4 kg/capita/year

(Niger), higher than that estimated for Bangladesh by the two aforementioned studies.

Although the low values of estimation by Balde et al. (2017) were correspondent to

developing countries that lack the credible inventories and sound legislation (0.4

kg/capita/year: Niger; 0.5 kg/capita/year: Sierra Leone, Rwanda, Malawi, Madagascar,

Guinea-Bissau, Ethiopia, Central African Republic, and Burundi), it is not plausible that

４３
Bangladesh generated far lower E-waste than countries having 2-6 times less per capita gorss

domestic production (GDP).

In summary, per capita yearly E-waste generation in Bangladesh may be in the range

of 0.9 to 1.9 kg/capita as estimated by Balde et al. (2017), Mott Macdonald (2018), and

CERM (2019). A more accurate figure for E-waste generation can be determined if a national

E-waste inventory is established with reliable material flow records. However, instituting a

holistic E-waste inventory is hardly achievable in the near future. Therefore, it is

recommended that comparative research is conducted on the countries equipped with a

complete inventory of E-waste, accompanied by an understanding of the countries’ socio-

economic status.

3.2.2 E-waste generation by devices

While many studies estimated the total generation of E-waste in Bangladesh, few

studies estimated generation based on the types of E-waste. Studies on the estimation of

typical E-waste items are summarized in Table 3-5. It should be noted that a direct

comparison of study results is not proper because they applied different datasets and

methodologies for their estimation; additionally target items included in each analysis varied

depending on the scope of the research. Reza and Yusuf (2012) and Re-Tem (2015) carried

out to estimate the generation of several electronic devices. The original units of estimated

amounts by Re-Tem (2015) were pieces rather than a weight-based unit, while CERM (2019)

converted the unit to follow weight dimension by applying the unit weight of each item using

the US EPA method.

４４
 Table 3-5. Summary of estimates of E-waste by item in Bangladesh from previous studies
(unit: ton/year)
Medical
Ship
Mobile Comp CFL & Dental
Study TVs ACs Freezer Fans IT Breaking
Phones uters bulbs Equipme
Yard
nt Waste
Reza and Yusuf
7,700 17,960 - - - - - - - -
(2012)

ESDO (2014) 21,100 30,700 860,000 - - 3,200 - - 39,500 8,860,000

Re-Tem (2015) 152 120 1,880 950 3,300 350 - - - -

CERM (2019) 6,000 30,000 100,000 1,700 300,000 1,100 20,000 550 - -

-: not estimated in the study

ESDO (2014) seems to have overestimated the E-waste generation from ship

breaking yards. Their calculation assumed every container in the imported scarp ship was

fully occupied by E-waste, which may not be true in reality. The debris of ship breaking yards

may be incorporated into E-waste flow and will be counted in other E-waste items again

depending on their types, for example, computers, televisions, freezers, etc. It appears that

incorporating ship-breaking yards in an E-waste inventory may not be reasonable. The over

estimation by ESDO was already criticized in the previous chapter, and the too-large number

may be attributed to the excessive accounting of E-waste generation from ship breaking yards.

According to ESDO (2014), the second item generating large amounts of E-waste was

televisions. CERM (2019) rated freezers as the largest e-waste item followed by televisions.

Therefore, televisions and freezers seem to be the main contributors to E-waste if the

unsound estimations for ship breaking yards are removed. CERM (2019) surveyed E-waste

amounts handled by types of recycling sectors including shipbreaking recycling sites, an E-

waste recycling site (which only processed printed circuit boards), another E-waste recycling

site (which only processed E-waste from public sectors by contracting), Bhangari shops

(private secondhand goods dealers), exporters, and educational institutions. Their survey

results are presented in Table 3-6. When the survey was conducted, it seemed there were only

４５
two E-waste recycling sites in operation with legal licenses. The visits were made in 2018;

there were only two companies obtained Environment Clearance Certificate before 2018

(Table 3-7). CERM's (2019) survey revealed that the hotspots in E-waste flow were Bhangari

shops, and the ship recycling sector was the second-largest E-waste source, but not to the

extent suggested by ESDO. Currently, there are more than two E-waste recycling companies

enrolled by Environment Clearance Certificate; thus, the current status of E-waste flow may

be different from the survey results by CERM (2019). Regardless of the rise of E-waste

companies with public licenses, the importance of including informal E-waste recycling

sectors represented by "Bhangari shops” should be noted.

Table 3-6. Total amounts of E-waste in recycling sectors in Bangladesh

(unit: ton/year)
Ship E-waste E-waste Bhangari E-waste Educational
Recycling Recycling I Recycling II Shops/Dealers Exporters Institutions

4,000 1,146 700 6,217 1,000 220

Source: CERM, 2019

４６
Table 3-7. E-waste recycling companies licensed by environmental clearance in Bangladesh
Number Name and Activities Environmental clearance Subordinate Comments
address of the time office
organization
1 Azizu Re- E-waste 18.04.2013 Narayanganj The first
Cycling and E- management 359th meeting (A / 08) district licensed
Waste Company Name change in 396th institution
Ltd. (formerly - meeting (O / 04)
Azizu Trading
Company)
Sang-Del Para,
Kutubpur, Thana:
Fatulla, District:
Narayanganj

2 Green Bangla E-waste 07.08.2014 Dhaka Institution

Corporation management 36th Meeting (A / 26) metropolis holding 2nd
403-404 Tejgaon clearance.
Shi / A, Phone: 01719-
Dhaka-1205 2843

3 JR Enterprise E-waste 400th Meeting (A / 25) Dhaka district Institution

Fulbaria, management 01/11/2018 holding 3rd
Hemayetpur, clearance.
Savar, Dhaka Phone: 01719-
2843

4 Messrs. Zaman E-Waste 402nd Meeting (A / 26) Dhaka

Enterprise Management 10/01/2018 metropolis
440, Jalalabad
Iron Steel and
Machinery
Market,
Muradpur,
Kadamtali,
Dhaka
5 Messrs. Rustam E-waste 402nd Meeting (A / 26) Dhaka
Enterprise management 10/01/2018 metropolis
265, Nurerchala
East, Bhatara,
Dhaka

6 Messrs. Delwar E-Waste 402nd Meeting (A / 26) Dhaka

Enterprise Management 10/01/2018 metropolis
265, Nurerchala
East, Bhatara,
Dhaka

7 Messrs. Yusuf E-waste 402nd Meeting (A / 29) Dhaka

Enterprise management 10/01/2018 metropolis
265, Nurerchala
East, Bhatara,
Dhaka

Each of the institutions mentioned in serial numbers 5, 6, and 7 are located on the plot side by side.
Each institution has applied for environmental clearance individually. Each organization has its no-
objection letter from local authority, as well as a fire license and income tax certificate. Environmental
clearance has been issued after on-the-spot inspection of each institution.

４７
 Further study is needed to find out the exact hot spot of E-waste flow and to monitor

the status of the illegal business on E-waste recycling. According to CERM's survey, the

Bhangari shop, representing the informal sector, accounts for 50.2% of E-waste recycling.

However, this estimation by survey may not represent the real parameter in the current

situation of E-waste management in Bangladesh because the number was only associated

with the recycled amounts of e-waste, not the whole generated E-waste amounts. In India, it

was estimated that nearly 85% of generated E-waste was treated by the informal sector

(Ghosh, 2020). The percentage revealed by the research pointed out the importance of

including informal recycling sectors into the public E-waste management scheme, and that

can be utilized to set the goal of the relevant policies. In Bangladesh, such a quantitative

estimation on E-waste flow should be amended to build a more concrete national inventory of

E-waste which must be beneficial for setting new policies and implementing thereof.

４８
 3.3 Analysis of current problems and main challenges for managing E-waste

3.3.1 Environmental pollution by improper E-waste management

The Center for Environmental and Resource Management (CERM) at Bangladesh

University of Engineering and Technology (BUET) presented a report on its survey results

regarding E-waste problems and implications entitled “Assessment of Generation of E-waste,

Its Impacts on Environment and Resource Recovery Potential in Bangladesh.” This section

summarizes the partial content of the study, focusing on environmental impact assessments in

E-waste recycling sites.

CERM (2019) evaluated the health impacts for employees at E-waste recycling

centers by using the risk assessment per the guidelines of the United States Environmental

Protection Agency (US EPA) (US EPA, 1989). Briefly, the risk assessment consists of three

steps: 1) hazard identification by monitoring the background concentrations of toxic

substances; 2) estimation of intake amounts by considering the likelihood of exposure to

toxic materials based on working time and expected intake amounts from several activities

such as drinking water, inhalation, etc.; and 3) modeling the toxicity response given the

dosage estimated by the second step. In the study by CERM (2019), the risk assessment was

performed for lead (Pb), cadmium (Cd), and chromium (Cr) using the conditions of a typical

E-waste recycling site in Bangladesh. The risks for three age groups of workers—below 15,

15 to 25, and above 25—were investigated separately. For each substance, the risk of

inhalation (air) and ingestion (water) was evaluated. Atmospheric metal concentrations were

referred from Islam et al (2015), but complete information on the reference was not

documented in the CERM (2019) report such that tracking the reference was impossible.

Aqueous metal concentrations were obtained by measuring concentrations in the water and

soil samples within the survey region.

４９
 According to the risk assessment, all three age groups of workers were at risk by

inhaling Pb, Cd, and Cr at carcinogenic levels. In the case of ingestion, only Pb presented a

carcinogenic risk, and this risk was present for all three age-groups. This study presented the

first risk assessment of the E-waste recycling site in Bangladesh, thus worthy of examination

and discussion. However, the study has some limitations that should be overcome in a future

study. First, this study did not count the risk due to dermal contact between workers and

hazardous elements in E-waste. Also, the types of target contaminants included were very

limited. For example, halogenated compounds including polybrominated diphenyl ethers

(PBDEs), polybrominated dibenzodioxins and furans (PBDD/Fs), and polychlorinated

dibenzodioxins and furans (PCDD/Fr) were not included in the assessment despite these

chemicals having been found in high concentrations at many E-waste recycling sites in other

countries (Brigden, 2005). According to an analysis of soil samples near the E-waste

recycling site in Dhaka (Islam et al., 2015), the average concentrations of the six tested

metals followed the order of copper (Cu) > nickel (Ni) > lead (Pb) > chromium (Cr) > arsenic

(As) > cadmium (Cd). It should be noted that this order was obtained through a simple

comparison of average values rather than using a statistical test; the averages and standard

deviations of each sample set are given in Table 3-8. These results indicate that more metallic

contaminants should be considered when conducting a risk assessment—for example, Cu and

Ni.

Table 3-8. Heavy metal concentrations (mg/kg) in soils near the E-waste processing site in
Dhaka, Bangladesh, evaluated through triplicate sampling at five sites (Islam et al., 2015)

Chromium Nickel Copper Arsenic Cadmium Lead

Mean ± SD* 140 ± 112 525 ± 255 553 ± 217 67 ± 34 34 ± 31 350 ± 282

Range 54–333 315–923 175–701 24–103 5.2–80 148–842

*SD: standard deviation.

５０
 The report by CERM (2019) pointed out the environmental concerns from the final

disposal activities of E-waste. Many informal E-waste recycling sites perform open burning

of wires/cables to recover copper, and the burning results in the release of harmful

compounds like dioxins, furans, and heavy metals. Chowdhury (2014) found a high

concentration of iron (Fe), lead (Pb), cadmium (Cd), and Chromium (Cr) in surface waters

and soils near the area where many E-waste processing sites are located. However, it is

unclear whether the contamination is due to the E-waste recycling site or other factories,

especially for the tannery industry. Therefore, a more detailed study is needed to clarify the

origins of pollution. Besides, it was reported that around 96 % of E-waste in Bangladesh ends

up in landfills (CERM, 2019). Without environmental sound management of these landfills,

toxic compounds in E-waste may be transported into the surrounding environment and

produce public health risks.

3.3.2 Absence of regulatory framework

A piece of legislation entitled ‘Hazardous Waste (E-waste) Management Rules’

(MOEFCC, 2019) (hereby “E-waste Rules” or “the rules”) was prepared to regulate the

management of E-waste in Bangladesh in an environmentally sound manner under the upper

level of the Environmental Conservation Act (MOEF, 1995). The rules stipulate the

responsibilities of stakeholders for achieving EPR. While the responsibility is well organized,

several drawbacks should be noted and needed to be fixed through amendment of the rules or

issuing a Statutory Regulatory Order (S.R.O) in the future. Many information regarding the

rules was already mentioned in Section 3.1.2., and this section focused on pragmatic

problems in the rules.

The overarching method of enforcing stakeholders to follow their assigned

responsibilities is not clear. An economic incentive or penalty needs to be designed to

５１
overcome this current limitation of rules, as the command and control is the most inefficient

way of environmental regulation from an economic perspective. The mechanism to achieve

the policy goals should be thoroughly considered in the context of current situation of e-waste

management in Bangladesh. For example, producers and assemblers cannot handle the

investment necessary to build PROs unlike developed countries. In developed countries,

electronic producers are usually large companies with tremendous market share such as

Samsung and LG in Korea. However, in Bangladesh, there is no manufacturer (except for the

Walton) with a large market share in the areas of televisions, computers, or mobile phones;

instead, these markets depend on small businesses of assemblers or import of assembled

products from other countries (ESDO, 2010). Such a gap between the model countries for

legislation and the actual status of Bangladesh could be reduced after obtaining a full

understanding of the country's socio-economic culture, local characteristics, and customs, as

suggested by Agamuthu et al. (2009).

There are 71 different products for collection and recycling in the E-waste rules. The

list of electrical and electronic products/equipment ranges from household appliances to

monitoring and control instruments, medical equipment, automatic machines, and IT and

telecommunication equipment. It may be difficult to control and manage such a large number

of devices by the EPR system at once. Before the enactment of the rules, reconsideration may

be required on the range of target items to confirm the national capacity.

It will be better to emphasize the role of the collection center by addressing the more

concrete function and scope of the facility. Empowering the center by incorporating the role

of dismantling and recycling may be a more feasible option, as this will increase

opportunities for both capital and materials flow into the facility. Besides, building a large

infrastructure taking a charge only in a collection may not be effective in the current situation

５２
of Bangladesh. Given that there are many small informal recycling sites, redistribution of

collected E-waste at the collection center to small recycling sites is indeed inefficient. To

encapsulate the prevailing informal sector into the formal E-waste management system, the

concept of the collection center may need to be reconsidered.

The E-waste Management Rules suggests an annual E-waste collection target. The

target e-waste collection for the first year of implementation of the Rules is 10 %; and the

target gradually increases by 10 % until the fifth year after which it remains constant. The

basis of the collection target is the total amount of E-waste generated in Bangladesh.

However, there is no certainty of having an inventory of E-waste materials flows in

Bangladesh. Therefore, an exact target volume for E-waste collection cannot be established.

Such an unreliable policy goal may hinder the implementation of E-waste management. The

development of an E-waste inventory should be accompanied by legislation. During the

preparation of the inventory, other alternative statistics (e.g., estimated per capita E-waste

generation referring to other countries’ values) can be used as a basis for the collection

target. Moreover, the recycling target was not mentioned in the legislation. The recycling

target should be designed alongside the collection target to achieve sustainable E-waste

management in Bangladesh. The idea of a target recycling rate should be incorporated along

with a proper definition of “recycling,” to prevent perfunctory recycling. Whilst target

collection and recycling rates are designed, an E-waste inventory should be prepared for

establishing the exact basis of these regulations.

In summary, some limitations and weakness should be noted to amend the E-waste

rules in the future. For example, national collection and recycling target rates should be

clarified. A more simple and step-by-step approach for target collection and recycling rates

should be prepared for reflecting the current situation of E-waste recycling. The method of

５３
cost contribution and penalty by producers should be determined. The overall mechanism to

trigger the stakeholders to follow the responsibility is lacking. An economic incentive needs

to be designed to overcome the current limitations of the E-waste rules. Figure 3-2 shows the

summary and weakness of new E-waste rules.

Figure 3-2. Summary and weakness of new E-waste rules

3.3.3 Absence of partnerships with stakeholders

Several stakeholders have been involved in the management of E-waste including

producers, importers, retailers, consumers, collectors, recyclers, NGOs, and government.

Alam and Bahauddin (2015) suggested that building partnerships with stakeholders including

private enterprises and manufacturers needed to bring all actors to the table of E-waste

５４
management. Without communication and partnerships among stakeholders, it is difficult to

establish a sound and sustainable management of E-waste. In particular, the majority of E-

waste is collected and managed by the informal sectors in Bangladesh, as evidenced by a

large proportion of E-waste treated by Bhangari shops (Table 3-6). The informal sectors

largely process E-waste in a rudimentary way, causing health risks to humans and

environmental pollution due to improper disposal. To avoid the problems aroused by

anonymity and ensure transparency of informal sectors, it is recommended to invite the

informal recyclers without imposing regulations or fine, as past trials in regulating the E-

waste sector using the carrot or the sticks theory proved unsuccessful (Alam and Bahauddin,

2015).

The most difficult aspect of building new partnerships between stakeholders is

integrating the informal sector into the formal E-waste management network. Many informal

recycling sites were developed before the E-waste Rules were drafted. With the advent of the

newly designated formal sector, the governance of the informal sector is very complex and

requires sincere consideration from authorities. Existing illegal businesses may hinder the

settlement of formal recycling facilities through competition, and invoking governance

failure with over-reporting of the recycling amounts to receive a distorted subsidy (Kojima et

al., 2009). The actual conditions of informal recycling sites are not transparent, and related

documentation is limited because the illegal sites have been reluctant to participate in surveys

carried out by governmental institutions or consultants from abroad. Local experts carry an

important role in uncovering such information.

５５
 3.3.4 Environmental awareness on E-waste

CERM (2019) criticized the lack of worker’s awareness of the harmful effects of E-

waste and unsafe recycling practices. According to a field survey conducted at recycling sites,

only 7% of respondents were aware of the existence of toxic substances in E-waste. Improper

dismantling and recycling practices have resulted in workers experiencing dangerous dust

emissions (24% of respondents) and workplace injuries (15% of respondents) such as

injuries to hands, legs, and head. In many sites, personal protective equipment including

masks and gloves was not available, and E-waste stockpiles were often stored in open places.

Figure 3-3 illustrates the true conditions of the E-waste recycling site in Bangladesh.

Figure 3-3. An example of the current E-waste recycling practices in Bangladesh. These
include (a) storage of E-waste in an open area; (b) recycling activities without proper
personal protective equipment; and (c): hand injury due to handling of sharp E-waste stocks
(cited from CERM, 2019)

According to a survey of residents in Bangladesh (Islam et al., 2016), more than 90%

of households were not even aware of the terminology of “E-waste.” Raising the public

awareness on environmental issues ,especially on E-waste, from household to industry setting

is crucial for the successful implementation of E-waste policy. For example, a newly

developed collection system will be effective only if the residents are aware of the collection

５６
site and time period for drop-off. In line with the E-waste Rules, various obligations to

increase public awareness will be assigned to various stakeholders groups including

government, manufacturers, assemblers, re-processors, and importers of electric/electronic

products. Many instruments for spreading awareness are presented in the rules, including

publications, leaflets, informational booklets, advertising posters, and digital methods

(websites, e-mails, SMS, TV, newspaper, SNS, etc.). The government should devise proper

monitoring methods to check the actual operation status of public awareness programs, which

will be assigned to E-waste management industry members as a prerequisite for their

application of registration within the industry.

3.3.5 Financial security

Financial security is also necessary for a sustainable E-waste management system.

like municipal solid waste management, E-waste management incurs the costs in the

collection, transportation, and final disposal of waste. Furthermore, concerns for safety,

public health, and the environment need to be addressed because E-waste stockpiles contain

high concentrations of toxic and hazardous materials. In developing countries, acquiring

funding for implementing E-waste management programs is often difficult because of limited

national budgets and lack of funding mechanisms. In many developed countries, large

companies producing electric/electronic devices can establish PRO under the framework of

EPR. The PRO’s capital facilitates the successful implementation of E-waste management by

supporting the cash flow necessary for the whole process of E-waste flow. A breakthrough is

required in developing countries to conceive appropriate funding sources and mechanisms. It

is worth to mention that the Bangladesh Bank (Central Bank) under Sustainable Banking

Division has created a fund of BDT. 400 crores, to provide loan at a low-interest rate, to the

５７
entrepreneurs of environmentally friendly Products/Initiatives/Projects. In their list of 54

items, establishing E-waste Management Unit/Plant is included in the list.

3.3.6 SWOT (strength/weakness/opportunity/threat) analysis of E-waste

management in Bangladesh

To clearly understand the context of E-waste management in Bangladesh, a SWOT or

“Strength/Weakness/Opportunity/Threat” analysis was performed. The main interest of the

SWOT analysis was sustainable E-waste management in terms of establishing

environmentally benign E-waste management, as well as increasing the nation’s wealth to

support the E-waste management framework. The highlights of the SWOT analysis are

summarized in Table 3-9 and the details were described in the following paragraphs.

５８
 Table 3-9. Summary of the SWOT analysis for E-waste management in Bangladesh

Strengths (S) Weaknesses (W)

Internal ⚫ Abundant supply of labor ⚫ Limited regulatory measures

Factors ⚫ Expertise of local practitioners ⚫ Lack of an E-waste collection network

⚫ Low levels of technical expertise within

the existing informal E-waste system

Strategies ⚫ Utilize abundant labor force incorporating ⚫ Build concrete legislation and association

the technicians from informal sectors regarding E-waste management

⚫ Periodical education and training of

workers

Opportunities (O) Threats (T)

External ⚫ Economic potential of resource recovery ⚫ Illegal import of E-waste

Factors from E-waste

⚫ Increasing volumes of global E-waste

Strategies ⚫ Harness the resource from E-waste ⚫ Build national inventory of e-waste flow

including noble metal in a safe manner ⚫ Planning policy in an accordance with

international regulation on transboundary

movement of E-waste

In achieving sustainable E-waste management, the strengths of the system in

Bangladesh stem from the labor power provided by the people. The current population of

Bangladesh is around 160 million people, and the per capita gross domestic production (GDP)

is $ 1,888. Large populations with low labor costs can support the advent of job markets

necessary to support cleaner E-waste material flows. In the existing informal E-waste

recycling sites, many workers who are skilled in the practice of E-waste recycling, such as

dismantlers. They can serve an important role in establishing a new framework of sustainable

E-waste management through transferring their knowledge and skills to new entrants.

５９
 The weaknesses of Bangladesh’s E-waste management arise from the lack of a

formal management system as well as using low level of technology. Although there is a draft

E-waste management rules , the overarching method of enforcing the rules is lacking, and the

current cultural and economic landscapes of Bangladesh are not fully reflected in the law.

Moreover, the Bangladesh law follows the tradition of common law; thus, the power for the

government to implement the documented rules may be weaker than many countries

following the civil law including Korea, Japan and the countries in the European continent,

except for the United Kingdom. The limited legal framework has resulted in the absence of a

comprehensive E-waste management system, including the E-waste collection network. An

interview subject from the by CERM (2019) interview, who was employed at an E-waste

recycling site with public license, criticized that the tendency for private consumers to

dispose of E-waste into the informal sector as a result of the lack of a public collection

system. This disposal tendency made formal sites vulnerable to competition between informal

businesses through a reduction in the incoming volume of E-waste. Finally, the low level of

technology in informal sectors is a critical element of environmental pollution and health risk

for workers. For example, many informal sites utilize open-burning to recover valuable

metals such as copper (Cu) from E-waste because of a lack of alternative technologies at

comparable or lower costs. However, open burning of E-waste stockpiles can pollute nearby

atmospheric environment and water ways by releasing harmful substances.

There are external opportunities in how Bangladesh establishes and sustains an E-

waste management system. First, an increasing global demand for rare metal resources will

facilitate the growth of the E-waste recycling business. Profits from resource recovery of E-

waste can be maximized with the synergy of abundant labor, as previously mentioned as a

strength in Bangladesh. The increasing demand for resources is stemming from the market

growth of information and communications technology (ICT). Again, the expanding market

６０
of ICT will result in the increasing burden of E-waste and thus need for its management. In

the future, Bangladesh can assume an important role in E-waste recycling with a

monopolistic position.

The main threat to E-waste management in Bangladesh is the illegal import of E-

waste from other countries. E-waste smuggled into the country is usually transferred into

informal E-waste recycling sites, where environmental risks prevail. There is no overseer to

track illegal E-waste import, and no inventory exists to count E-waste flow. A well-

established national scale E-waste inventory is necessary to supervise the flow of externally

sourced E-waste.

６１
4 International efforts and implications on sustainable

management of E-waste

In the Basel Convention and in advanced countries, E-waste is classified as hazardous

waste (Basel Convention, 2017). Under the Basel Convention, the Mobile Phone Partnership

Initiative (MPPI), Partnership for Action on Computing Equipment (PACE), and partnerships

with other international organizations such as Solving the E-waste Problem (StEP) are

implemented for the proper management of E-waste (Basel Convention, 2020b). Their shared

purpose is to promote environmentally sound management of E-waste through the

development of technical guidelines on the identification, transportation, transboundary

movement, and treatment of E-waste (Basel Convention, 2020b). In advanced countries such

as those in the EU, regulatory measures are strengthened to safely manage e-waste by

restricting the use of hazardous substances in Electronic and Electrical Engineering (EEE),

curbing the generation of hazardous waste, and giving producers the responsibility of treating

the E-waste (Schumacher, 2016). However, E-waste is still entering some Asian countries,

and they perform improper treatment methods in recovering materials from the waste. These

operations include open burning, manual separation, and acid leaching. Workers do not wear

protective equipment nor do they realize that they are handling hazardous materials.

Chapter 4 thus discusses the process of legislative activities and establishment of a

management system for the environmentally sound management of E-waste in USA,

European and Asian countries with a focus on (the Republic of) Korea. In addition, the

section aims to explain the implications of research and legislation on E-waste management

systems in various Asian countries, including India and China. As a result, this chapter

intends to present a policy tool that can be applied in Bangladesh based on the status of e-

waste and management systems in USA, European and Asian countries.

６２
 4.1 Sustainable E-waste management in advanced countries

4.1.1 USA

In the USA, the Resource Conservation and Recovery Act (RCRA) requires the safe

management of waste using a comprehensive life cycle approach, i.e., from waste generation

to final disposal. In the RCRA, hazardous wastes are identified using the Hazardous Waste

Identification (HWID) procedure; some E-waste, such as cathode ray tubes (CRT), is

classified and managed as hazardous waste (US EPA, 2020).

There is no specific federal law for E-waste management, but 25 states have regulated

e-waste recycling, education, and other management activities (See Figure 4-1). Most states

have adopted E-waste management methods based on the concept of Extended Producer

Responsibility (EPR), and target items such as personal computers, televisions, and video

players are mainly generated from households (ERCC, 2020). Generally, the EPR policy

mandates that manufacturers of covered electronic devices register with the state, pay an

annual registration fee, and set up an E-waste recycling program in the state. The state may

also require recent sales data to inform recycling collection goals. If manufacturer collection

goals are not met, the state may increase the registration fee or charge an additional recycling

fee for every pound short of the goal. In addition to shifting end-of-life responsibility

upstream to the producer and therefore away from the public sector, EPR aims to incentivize

producers to incorporate environmental considerations into the design of their products and

packaging (Schumacher, 2016).

In California, an Advanced Recovery Fee (ARF) is implemented as a management

method for E-waste. It requires consumers to pay a fee when purchasing electronics, and the

fees are used to finance E-waste collection and recycling. The fee is set to USD $5 to $7

depending on the size of electronics (CalRecycle, 2020).

６３
 In Utah, state legislation requires manufacturers to provide education programs to

consumers about the proper recycling of electronics consumed within the state (Kahhat et al.,

2008). In these education programs, a method of recycling E-waste was included, and a

method of discharging it by consumers, including a take-back system, was explained

(Schumacher, 2016).

Figure 4-1. Map of states with E-waste legislation in USA (ERCC, 2020)

4.1.2 European Union and member states

The European Union (EU) has established the Waste Electrical and Electronic

Equipment (WEEE) Directive and Restriction of Hazardous Substances (RoHS) Directive for

the environmentally sound management of WEEE. The RoHS directive aims to reduce the

environmental impact of E-waste by restricting the use of certain hazardous substances in

Electrical and Electronic Equipment (EEE) to prevent adverse effects on human health and

the environment during the collection, recycling, recovery, and disposal of WEEE. The RoHS

directive prohibits the placement of EEE on the EU market when heavy metals (Pb, Cd, Cr6+,

and Hg) and brominated flame retardants (PBBs, PBDEs) in the EEE exceed certain levels

(European Union, 2002). In addition, the RoHS directive was revised in 2015 and added 4

６４
kinds of phthalate to be restricted in EEE, which became effective in July 2019 (European

Union, 2015).

Under the WEEE directive, manufacturers and importers of EEE are required to

collect and treat WEEE using environmentally sound management methods (European Union,

2012). The directive also set annual collection rates and established a producer-managed free

collection system of WEEE for consumers discharging E-waste. The annual target collection

rate is set at 65% of the average weight of products placed on the market in the 3 preceding

years in member states. For recycling and recovery, the directive set recovery and recycling

targets for 10 categories of WEEE on August 14, 2018 and 6 categories of WEEE on August

15, 2018. The recycling target for WEEE was set to a range of 55% to 80%, and the recovery

target was set to a range of 75% to 85% (See Table 4-1).

６５
 Table 4-1 Target recycle and recovery rate by WEEE category in EU

By Category Recycle and By Category Recycle and

(before 2018. 8. 15) recovery rate (after 2018. 8. 15~) recovery rate

1. Large household appliances Recycle 80% 1. Temperature exchange Recycle 80%

10. Automatic dispensers Recovery 85% equipment Recovery
4. Large equipment 85%
3. IT & telecommunication Recycle 70% 2. Screens, monitors, and Recycle 70%
equipment Recovery 80% equipment containing Recovery
4. Consumer equipment & screens 80%
photovoltaic panels
2. Small household appliances Recycle 55% 5. Small equipment Recycle 55%
5. Lighting equipment Recovery 75% 6. Small IT and Recovery
6. Electrical & electronic tools telecommunication 75%
7. Toy, Leisure & sport equipment
equipment
8. Medical device
9. Monitoring & control
instruments
Gas discharge lamps Recycle 80% 3. Lamps Recycle 80%

In Germany, Austria, and Belgium, all of which implemented the WEEE Directive, E-

waste management regulations were prepared in the form of decrees or ordinances according

to the situation of each country. In Germany, the Electrical and Electronic Equipment Act

(ElektroG) sets forth concrete obligations for all relevant stakeholders (manufacturers, traders,

municipalities, owners, and disposers) to manage E-waste. It focuses on waste prevention,

extensive recycling of waste, and reasonable checks concerning the possibility of preparing

for re-use of whole appliances or individual components (Chaudhary and Vrat, 2018).

An example of WEEE management flow in Germany according to the WEEE

Directive is shown in Figure 4-2 (Kristensen et al., 2012). Authorized and monitored by the

６６
“UmWeltbundesamt” (UBA, Federal Environment Agency), the responsible organization for

the overall waste system in Germany is called Elektro‐Altgeräteregister (EAR) and functions

as a clearing house. EAR takes care of the administrative tasks of registering producers,

calculating producers’ market shares, verifying that all producers have lived up to their EPR

responsibilities, and reporting compliance data to the EU. As an effort to minimize the free‐

rider problem and create a level playing field for all producers, EAR has placed a lot of

emphasis on enforcement measures to make sure that all producers have registered and are

paying their share of the WEEE treatment costs. To further minimize the free-rider problem,

Germany also requires that all producers, no matter their size, provide an insolvency‐proven

guarantee for the collection and treatment costs of the EEE they put on the market.

Figure 4-2. WEEE management flow in Germany (Kristensen et al., 2012)

Austria has established the Austrian WEEE ordinance (Elektroaltgeräteverordnung;

EAG-VO) to implement the WEEE Directive. As specified in the EU-wide WEEE directive,

EAG-VO places recycling responsibilities on manufacturers and importers. In addition, for

６７
the collection of WEEE, collection points have been established with a free return option to

the retailer or the local government, similar to a take-back scheme (Bogaert et al., 2008).

Belgium consists of three regions, all of which are more or less independent with

respect to environmental policy: Flanders, the Walloon region, and the Brussels capital region.

These three regions in Belgium have their own decrees for the implementation of the WEEE

Directive that account for most of the WEEE Directive's provisions. WEEE legislation is

fully implemented in Belgium, and companies selling electric and electronic products on the

Belgian market must be able to prove they are meeting their take-back obligations. Recupel

was established as the national agency in charge of WEEE collection by the WEEE Directive

(Bogaert et al., 2008; Recupel, 2019).

4.1.3 Japan

In Japan, the 3R (Reduce, Reuse, Recycle) initiative is being promoted for the

effective use of resources, and individual laws have been established based on type of waste.

Per the 3R initiative, the EPR policy in Japan started with the enactment of the Law for

Promotion of Effective Utilization of Resources in 1992 (MOE Japan, 2005). With the

implementation of EPR, individual laws came into force one-by-one that reviewed the

characteristics of different recyclable items. Each law had various stipulations on how to

impose responsibility on the manufacturers and share cost among relevant actors (Hotta et al.,

2009).

For the management of E-waste, the Home Appliance Recycling Act and Small E-

waste Recycling Act are being implemented. The Home Appliance Recycling Act covers 4

items of E-waste—televisions, washing machines, air conditioners, and refrigerators

６８
(including freezers)—and sets a target recycling rate of 55% to 82% by weight for each item

(MOE Japan, 2020). The Small E-waste Recycling Act covers 28 categories of small E-waste

and sets the collection target to 140,000 tons by 2020. The law requires producers to create a

take-back system to collect E-waste (MIC Japan, 2020).

In addition, management systems of E-waste in Japan stipulated a manifest system,

which is defined as a set of forms, reports, and procedures designed to seamlessly track waste

from the time it leaves the generator facility where it was produced until it reaches the off-site

waste management facility. Absent in the corresponding laws of other nations, this system

was introduced with the aim of integrating the management of waste processes from waste

generation to transport and final disposal, and to clarify the responsibilities of relevant

stakeholders (Lee and Na, 2010).

The Home Appliance Recycling Act and Small E-waste Recycling Act in Japan

provides a legal framework for assigning responsibilities to manufacturers, retailers, and

consumers within the flow of used home appliances, originating from consumers. As shown

in Figure 4-3, manufacturers are responsible for recycling used home appliances after they

are properly discharged by consumers. Upon the request of consumers, retailers are obligated

to take back used home appliances. In cases where consumers discharge used home

appliances to municipalities, consumers pay fees to municipalities for transportation and

recycling, who must then deliver the used home appliances to designated collection sites.

Transportation costs are paid separately. Retailers must then transport the used home

appliances to collection sites, which are designated by the manufacturers. Manufacturers are

required to either establish their own recycling facilities or commission commercial recycling

companies to fulfill their recycling obligations. They are additionally required to achieve

compulsory recycling rates to ensure effective utilization of resources. A comprehensive

６９
comparison of E-waste management systems among advanced countries is summarized in

Table 4-2.

Figure 4-3. E-waste flow in Japan (Hotta et al., 2009)

７０
 Table 4-2 Comparison of E-waste management systems in advanced countries

Country Legal basis Target Items Methods

USA - Laws in 25 states - Mainly generated from - EPR system

(There is no specific
federal law for E-waste)
EU - RoHS Directive
- WEEE Directive
Germany - Electrical and Electronic
Equipment Act
(ElektroG)
Austria - WEEE Ordinance
- Elektroaltgeräteverordnu
ng (EAG-VO)
Belgium - As the authority is at the
regional level, each of the
3 regions (Flanders,
Wallonia, Brussels) has
enacted its own decrees
and ordinances
Japan - Home Appliance
Recycling Act
- Small E-waste
Recycling Act
households - Advanced Recovery fee
- Televisions, personal Education program
computers, video
players, etc.
- 6 categories (more - Restriction of use of
than 100 items) hazardous substances in
established August 15, EEE
2018 - EPR system
- Free collection system
Collection rate
- Recycling and recovery
rate
- In accordance with the - Collection, recycling, and
WEEE Directive recovery targets are the
same as the WEEE
Directive
- In accordance with the - Collection, recycling, and
WEEE Directive recovery targets are the
same as the WEEE
Directive
- In accordance with the - Collection, recycling and
WEEE Directive - recovery target are the
same
as the WEEE Directive
- Collection system
operated by Recupel
- 4 items (televisions, - EPR system
washing machines, air - Take-back system
conditioners, - Recycling rates for 4
refrigerators items
(including freezers) - Collection targets for
- 28 categories of small small E-waste
E-waste

７１
 4.2 Eco-Assurance System for E-waste management in Korea

4.2.1 History on E-waste management in Korea

In Korea, the concept of recycling was first introduced in 1991 with the Waste

Control Act (MoE Korea, 2019a). At this time, a deposit-refund system was implemented as a

means to promote recycling, with packaging materials and other products like electrical and

electronic equipment (EEE) as target items. The deposit-refund system required a deposit

upon purchase of packaging materials and other products to cover the cost of recycling, but

refunds were only given for products that were actually recycled (MoE Korea, 2003). In this

system, there was no quantitative obligation on recycling; companies could appear to fulfill

their recycling obligations only by paying deposits without recycling and receiving refunds,

thereby limiting the rate of recycling.

In 2003, the Expanded Producer Responsibility (EPR) system was activated by

establishing Producer Responsibility Organizations (PROs) to improve collection and

recycling rates for EPR items (Jang, 2010; Rhee, 2016). The EPR system gives producers

quantitative obligations for recycling and sets recycling obligation rates for each product by

year, including packaging materials and other specific products (battery, fluorescent lamps,

EEE, etc.). Producers must achieve a recycling duty ratio compared to shipments annually; if

they fail to achieve the recycling duty ratio, they must pay recycling charges (i.e., a penalty).

With respect to E-waste, the Eco-Assurance System, which was separated from the

EPR system in 2008, was applied to reduce wastes and promote recycling activities. The

system aims to minimize environmental loads for 10 items of electrical products and

electronic devices from design and production to disposal. In 2014, the Eco-Assurance

System (Eco-AS) was expanded to incorporate 27 items and included most small- and large-

sized electrical products (Rhee, 2016). In 2020, the target items of Eco-AS were revised to

７２
reflect new types of E-waste such as internet routers, solar panels, and others. The revised

target items of Eco-AS were classified as 50 items under 5 categories (MoE Korea, 2020).

Figure 4-4. History on E-waste management in Korea

4.2.2 Management of waste by EPR system

The Extended Producer Responsibility (EPR) system in Korea was introduced to

place responsibility of recycling on producers and distributors in their determinations on

product structures and materials as well as choices on packaging materials. To promote

manufacture- and distributor-led recycling of wastes from Eco-AS products or packaging

materials, EPR imposes a recycling quota on manufacturers and distributors. If the recycling

quota is not complied with, a fine that may be greater than the cost of implementing proper

recycling shall be imposed upon the manufacturer and the distributor.

To fulfill collection and recycling obligations, producers can establish or join

Producer Responsibility Organizations (PROs). Producers pay a collection and recycling cost

７３
to the PRO, and the PRO tries to satisfy recycling targets to avoid paying a penalty. Therefore,

PROs manage the overall flow, including collection and recycling of target items, of the EPR

system to satisfy recycling obligations.

In 2003, items subject to the EPR system were set to include the existing items under

the deposit system, including packaging materials (3 items) and other products (4 items). In

2004, film-type packaging materials and fluorescent lamps were added to the EPR items.

With respect to E-waste, audio products and mobile communication devices were added in

2005, and printers, copiers, and photocopiers were added in 2006. Cosmetics (2007),

manganese batteries, alkaline manganese batteries, and nickel-metal hydride batteries (2008)

were also added such that the total items within the EPR was 15 in 2008, as shown in Table

4-3 (OECD, 2016).

Since 2008, wastes from the 15 EPR electric and electronic products have become

subject to the Eco-Assurance System under the Act on the Recycling of Electrical and

Electronic Equipment; this was done to increase E-waste recycling rates and to manage the

restrictions on the use of hazardous materials.

Since the country's EPR system was based on its SPR (Shared Producer

Responsibility) system, stakeholders including the government, consumers, and producers

experienced extended and non-independent responsibilities. Before the EPR system, the

government took responsibility for the disposal of non-recycled waste and the overall

responsibility to collect separated or sorted waste. In the EPR system, waste was easily

collected by separating and sorting waste to improve the recycling rate. Even though

producers paid the cost of recycling, the consumer eventually bore part of the recycling cost

because the recycling cost was reflected in product prices.

７４
 Table 4-3. EPR scheme and target items
EPR Legal basis Target item Remark
scheme
Take- Act on the Package Packages(metal can, glass bottle, paper
back with Promotion of (4) pack, synthetic resin packaging material)
recycling Saving and that are used to pack food and beverages,
targets Recycling of agricultural products, marine products,
Resources livestock products, cleansers, medicines
and cosmetics, etc.
Product Batteries (Mercury, Silver oxide, Lithium,
(11) Nickel- cadmium, Manganese, Nickel-
hydrogen), Tire, Lubricant, Fluorescent
lamp, Styrofoam float
Act on Resource Product (50 items) Transfer
Recirculation of Television, Refrigerator, Washing machine, Air Eco-AS
Electrical and conditioner, Computer, Audio, Mobile phone, Copier,
Electronic Fax machine, Printer, Automatic dispenser, Electric
Waste and End water purifier, Electric oven, Microwave, Food waste
of Life Vehicles disposer, Dish washing machine, Bidet, Air purifier,
Electric stove, Electric cooker, Water softener,
Humidifier, Iron, Fan, Blender, Vacuum machine,
Others

In Table 4-4, the recycling obligation rates from 2014 to 2020 are presented for target

items in the EPR system (MoE Korea, 2019b; KORA, 2020). The obligation rates for EPR

products have been continuously increased even though the actual recycling amounts and

rates were not meeting the obligation amounts and rates, respectively. For tires and lubricants,

the obligation rates were gradually increased from 76.5% in 2014 to 79.0% in 2020, and 72.6%

in 2014 to 74.3% in 2020, respectively. For fluorescent bulbs, the obligation rate rapidly rose

from 35.5% in 2014 to 94.5% in 2020. With respect to batteries and other products,

obligation rates were almost constant between 2014 and 2020. Most products have similar

levels of actual recycling rates when compared to Obligation rates. Some products, such as

silver oxide batteries, have not satisfied duty rates, but recycling rates have tended to increase

gradually. The obligation rates of packaging materials are generally set higher than the

obligation rates for products, but actual recycling rates and obligation rates are similar.

７５
 Table 4-4. Obligation rates and recycling rate in EPR system
Type Item 2014 2016 2018 2020

OR RR OR RR OR OR
Product Mercury battery 60.0 - 60.0 - 60.0 60.0

Silver oxide battery 56.0 25.0 67.0 45.4 72.2 65.2

Lithium battery 65.0 39.1 72.6 70.7 74.9 58.2

Battery
Nickel-cadmium battery 40.0 57.4 40.3 40.3 41.9 45.2

Manganese battery 21.6 4.7 21.6 24.8 22.5 27.5

Nickel-hydrogen battery 20.3 15.7 20.7 12.2 21.9 16.1

Tire 76.5 61.3 76.7 76.7 78.6 79.0

Lubricant 72.6 52.1 72.8 71.8 73.9 74.3

Fluorescent lamp 35.5 35.0 35.6 33.3 40.2 94.5

Buoys for farming marine products 28.0 27.3 28.1 - 28.7 29.4

Film for baled silage - - 30.0 - 31.3 38.4

Synthetic resin mats - - 79.8 - 79.9 80.4

Packing
Steel can 79.7 83.0 80.8 85.0 81.0 81.1
materials Metal
can
Aluminum can 79.1 78.0 79.7 76.0 79.7 79.7

Glass bottle 76.0 74.0 76.3 69.0 73.4 72.5

Paper pack 34.6 25.0 35.0 26.0 32.1 30.3

Colorless 81.2 81.8 80.0 80.0

Single
PET material
colored 81.2 80.0 82.9 80.0 80.0 80.2
bottle
Composite material 81.2 81.8 83.0 80.3

EPS 79.0 67.0 80.7 88.0 80.7 80.7

Synthetic
resin PSP 42.3 42.3 44.2 50.2
packing 67.0 88.0
PVC 69.0 73.5 69.2 30.0

Plastic container, tray 80.6 102.0 83.3 98.0 80.8 80.8

Others
Plastic film and sheet 60.3 78.0 65.2 104.0 66.6 75.9

Lubricant container 79.4 - 79.3 - 78.3 79.0

* OR: Obligation rate / RR: Recycling rate

７６
 4.2.3 Management of E-waste by Eco-AS

The purpose of the Eco-Assurance System (Eco-AS) is to minimize environmental

loads through systematic management of the entire life cycle of electrical products, electronic

devices, and vehicles—from design and production to disposal—in order to reduce wastes

and promote recycling activities.

The main contents of the Eco-AS can be divided into preventive regulations and

follow-up management regulations, as shown in Figure 4-5 (Rhee at al., 2018). Preventive

regulations include the Material Containment Standard Compliance and Compliance

Announcement, Material/Structure Improvement Guideline Compliance, Material/Structure

Improvement Evaluation Method, Annual Recycling Rate Compliance and Compliance

Announcement, and regulations to provide recycling information to stakeholders. Follow-up

management regulations include duties on electric and electronic equipment for

manufacturers and importers for recycling; electric and electronic equipment sellers’ duties

for collection and handover; end-of-life vehicle compliance with recycling rates; duties for

recycling end-of-life vehicles; duties of each organization; registration procedures for end-of-

life vehicles with respect to recycling; duties to report the end-of-life vehicles' recycling

results; and preparation and submission of management sheets. The purpose of the Eco-AS

was to encourage recycling with methodical management of E-waste and vehicles using a life

cycle approach for products.

In the Eco-AS, the recycling obligation was set as the recycling weight per capita by

category. This was done because products are multifunctional and include various parts and

functions, and in the existing EPR system, the method of setting recycling obligation rates for

individual products limited the advancement of recycling. Obligation and recycling amounts

for E-waste are shown by year in Table 4-5.

７７
 Figure 4-5. Summary of the Eco-Assurance System (Eco-AS)

The obligation amount for overall E-waste increased from 3.9 kg per capita in 2014

to 7.0 kg per capita in 2020. The actual recycling amount of overall E-waste are satisfied the

obligation amount, but in the case of medium and small home appliances, the recycling

amount is not satisfied. This is because the actual recycling amount is high for a large E-

waste, which has a relatively good collection and recycling system such as tack-back system,

and indicates that the collection and recycling system must be improved even for medium and

small devices.

７８
 Table 4-5. Recycling targets and recycled amount of E-waste by Eco-AS
Year Category Shipment Recycling target Recycled amount
(thousand
ton) (thousand (kg/capita) (thousand (kg/capita)
ton) ton)
Large home appliances 631.93 145.08 2.94 154.16 3.05
Post and
54.26 12.46 0.25 20.82 0.41
telegraph appliances
2014 Medium home
84.36 19.37 0.39 13.46 0.27
appliances
Small home appliances 68.89 15.82 0.32 11.82 0.23
Total 839.44 192.73 3.90 200.26 3.96
Large home appliances 610.59 178.80 3.51 195.53 3.80
Post and
62.90 18.52 0.36 29.00 0.56
telegraph appliances
2016 Medium home
87.80 25.88 0.51 25.23 0.49
appliances
Small home appliances 71.89 21.19 0.42 19.89 0.39
Total 833.18 244.40 4.80 269.65 5.24
Large home appliances 734.40 230.26 4.44 233.53 4.52
Post and
74.03 23.47 0.45 26.44 0.51
telegraph appliances
2018 Medium home
111.17 35.24 0.68 42.22 0.82
appliances
Small home appliances 70.57 22.37 0.43 20.56 0.40
Total 990.17 311.34 6.00 322.75 6.24

4.2.4 Materials and financial flow on E-waste management in Korea

In Korea, the material and financial flow in E-waste management is presented in the

cycle of 'production/distribution – consumption/discharge – collection/transportation –

recycling' (see Figure 4-6). Financial management for recycling of E-waste, including

accounting, is implemented by the Producer Responsibility Organization (PRO).

Material flow in the E-waste management system can follow the stages of 'producer

and importer' – 'discount store and retailer' – 'distribution center' – 'consumption' – ' local

７９
government' – 'recycling center and recycling facilities' – 'metal industry' – 'producer'.

Financial flow in the E-waste management system follows the stages of 'producer and

importer' – 'PRO' – 'discount store and retailer' – 'recycling center and recycling facilities'.

Within the producer and importer stage, producers/importers are tasked with paying

the recycling cost that is based on the target recycling rate to the PRO. The central

government decides the obligation amounts for E-waste recycling, working with producers to

enhance E-waste recycling. In addition, the central government should continuously monitor

the overall waste flow within the E-waste management system. The producers and PRO have

the obligation to satisfy recycling targets for their E-waste. If producers do not satisfy the E-

waste recycling obligation amounts, they must pay a fine due to the difference between real

recycling amounts and target recycling amounts.

In the stage of consumption and discharge, consumers have the responsibility to

discharge their waste to retail stores or collection places provided by local governments.

Consumers should discharge their E-waste to prevent mixing of E-waste with general waste

streams. Consumers can return E-waste to discount stores or retailers when the latter deliver

their goods to the consumers' houses. In this case, the PRO would pay collection costs to the

discount store or retailer.

Responsibility in the collection and recycling of E-waste belongs to local

governments and recyclers to collect on time and to transport safely. Recyclers should work

to recycle in accordance with the Waste Control Act and ensure to separate raw materials

from recycling materials. The PRO should pay a collection cost and recycling cost to the

recycling center. Recycling centers should report recycling rates to the central government to

determine the real recycling amounts within the E-waste management system.

８０
 Figure 4-6. Materials and financial flow on E-waste management in Korea

4.3 Implications of sustainable E-waste management

4.3.1 Implications on E-waste management in Asian countries

As the production and consumption of EEE increases internationally, E-waste

generation also increases in most Asian countries. Some Asian countries are importing E-

waste to recover valuable substances. However, in Asian countries, material recovery from E-

waste is performed in non-environmentally sound manner without considering human health

and operational circumstances (Ikhlayel, 2018). With E-waste being imported as well as

generated domestically, E-waste management in Asian countries faces great challenges.

Grouped by geographic region, the major issues of E-waste management in Asian countries

as reported by the literature are shown in Table 4-6. In most Asian countries, only a small

amount of E-waste is treated formally, and most is handled through open dumping and

informal sectors. Hence, it is suggested that open dumping and informal treatment of E-waste

８１
should be replaced by formal collection systems through awareness programs for workers and

the public.

In most Asian countries, E-waste has been processed through informal sectors such

that it is difficult to identify specific E-waste streams or the amount of E-waste treated. In

informal sectors, E-waste is segregated manually, and participants in its segregation include a

diverse distribution of people, from children to the elderly, who work without safety

measures. This is because E-waste handlers (consumers, collectors, recyclers, etc.) are not

aware of the adverse effects on human health and the environment that may be caused by

hazardous substances in it. Moreover, some Asian countries lack the technologies and

facilities to treat E-waste safely, and policies and regulations for overall management of E-

waste are insufficient.

The needs for E-waste management in some Asian countries, which must be met to

convert E-waste stream from informal sector to formal sector, can be addressed by (1)

developing policies and guidelines, (2) creating education and training programs, (3)

improving treatment technology, and (4) installing management facilities.

To prepare for meeting these needs, basic capacity building is necessary. Additionally,

basic information on types and amounts of E-waste generated should be considered to aid in

developing policy designs, creating technical guidelines, and applying simple technologies

within E-waste management systems.

８２
 Table 4-6. A review of E-waste management issues and solutions in Asian countries by
research aspect and geographic region.
Approach/
Research aspects Countries Major Issues and solutions Ref.
method
Primitive Experimental China The environmental problem of E-waste recycling is Chen et al.
recycling analysis growing, and actions should be taken to lessen the (2010)
detrimental impacts of E-waste disassembly.

E-waste Application Philippines There is a necessity to strengthen the recycling Peralta and
estimates of the model market, as this will aid in diverting E-waste from Fontanos
landfills, thus extending landfill life and giving a new (2006)
source of materials recovery.

Challenging Review Asian Asian countries, particularly in Asia and Africa, are Herat and
issues of countries facing a serious problem with the growing E-waste Pariatamby
managing E- amounts due to the absence of policies and (2012)
waste in Asian infrastructure to handle the issue sustainably.
countries Although E-waste is a problem because of its
hazardous nature, proper management with recovery
is also a solution to the deficiency of the natural
resources that producers of e-products depend on.

E-waste Analyses China Efficiently managing E-waste has become a global Lu et al.
estimates problem, particularly in Asian countries such as (2015)
China, where both advanced treatment technologies
and efficient management policies are lacking.

Conceptual Mixed India The relevant literature in E-waste research topics in Heeks et al.
models of E- methods Asian countries is relatively limited. It has (2015)
waste strategies concentrated on three main issues: (1) the extent and
and E-waste impacts of E-waste, (2) international trade, and (3)
strategy legislation aspects
determinants
Policy trends Review Asian Policy trends for E-waste management in Asia Pariatamby
countries suggest a growth path towards sustainable E-waste and Victor
management. (2013)

Recycling and Review India A huge quantity of E-waste is produced, but only a Awasthi et
human health small amount is treated formally; the remainder is al. (2016)
handled through the informal sector. The results
suggested that the open dumping and informal E-
waste recycling systems should be replaced by the
best technology and regular awareness programs for
workers and the public.

８３
 Scenario Life Cycle Jordan Landfills as the ultimate sink for all components of `
development, Analysis the E-waste is the worst scenario and should be
environmental (LCA) avoided. The most promising scenario features
impact integrated E-waste processes based on the concept of
assessment IWM, including recycling of metals (precious and
non-precious metals), plastic incinerating, and
management of the hazardous the content of PCBs.
For such scenario, the best environmental
performance can be obtained using mobile phone
treatment.

Challenges of Review Bangladesh In Bangladesh, E-waste management is limited due Masud et al.
E-waste to insufficient budget and infrastructure. E-waste (2019)
management management hierarchy was suggested in the order of
(1) E-waste to energy, (2) repossession, (3)
dismantling, (4) recycling, (5) reusing, and (6)
dumping.

4.3.2 Policy design for E-waste management

In most advanced countries, policies based on the Extended Producer Responsibility

(EPR) system are in place to manage E-waste. Designing an EPR system with clear and well-

defined roles is essential for all actors including producers, consumers, authorities, and waste

managers. However, it is not easy to immediately introduce the EPR system in some Asian

countries because they often lack the infrastructure necessary to adopt the EPR system for e-

waste management, and mostly its flows occur within informal as opposed to formal sectors.

Prior to introducing the EPR system in such some Asian countries, it is first necessary to

understand the characteristics of each country's E-waste management system through small-

scale demonstration projects in specific regions. Additionally, collaboration with stakeholders

should occur when designing a policy for E-waste management to allow them to participate.

Before applying the EPR system in some Asian countries, the 3P's principle should be

adopted as a framework for designing national policies to manage E-waste. Within E-waste

management systems, it is very important to identify the identity of the ‘Polluter’. “Polluters”

８４
should be given the responsibility to manage E-waste properly and to prevent adverse effects

upon disposal. In many countries, the 3P’s principle has been applied to manage wastes

including E-waste. The subject of ‘polluters’ in the overall E-waste management has been

legally defined through regulations to distribute the responsibility of E-waste management to

several groups of stakeholders. The subject of ‘polluter’ can be divided into producers and

distributers, consumers, collectors, and processors (recyclers, disposers, etc.).

Responsibilities of producers and distributers are mainly assigned by setting E-waste

collection and recycling targets. Penalties are imposed if producers and distributers do not

satisfy their responsibilities of achieving these targets. For consumers who discharge E-waste,

a method is adopted which gives them the responsibility to separate it from other waste, or to

pay its treatment fees when purchasing EEE in the form of advanced recycling (or recovery)

fees. Collectors and processors must comply with relevant environmental laws and

regulations to safely transport E-waste and to minimize contamination that may affect the

surrounding environment in the processing of E-waste. In this way, the 3P's principle can be

established by identifying the 'polluter' related to E-waste management and subsequently

charging them with behavioral responsibilities.

As a preliminary step for introducing the EPR system, small-scale demonstration

projects can be adopted as a Pre-EPR (Preliminary EPR) system. The Pre-EPR system is a

process of providing a systematic means to partially transition E-waste streams from the

informal sector to the formal sector. In order to move E-waste streams into the formal sector,

a financial benefit for managing the collection of E-waste, including surveying of generation

amounts and monitoring, is a very important factor.

For each province or region of a country, managing associations composed of

producers and importers can control E-waste collection with the aid of financial benefits.

８５
When the managing association is established, producers and importers will pay a fee to the

association. The association can use the fees to pay collectors in a structured manner. Thus,

E-waste can transition from the informal to the formal sector due to financial benefits for

collectors. In conclusion, in Pre-EPR, it is very important to prepare for comprehensive

management of e-waste from generation to treatment and to provide a financial means for the

collection of E-waste to flow through formal sectors.

Potential issues in designing an effective E-waste management system have been

identified and grouped into 5 categories such as legal regulation, system coverage, system

financing, producer responsibility, and ensuring compliance. The implementation of the pre-

EPR system in some Asian countries is slightly different from that of the EPR system. The

main methods of implementing the Pre-EPR system are shown in Table 4-7.

Table 4-7. The method of Pre-EPR system

Pre-EPR system tools Methods

Collection programs
Regulatory approaches
Voluntary industry practices
Financial mechanisms
- Control by the managing association with producers
- Payment of collection fees from managing association to
collectors
- Creation of managing associations by producers and
importers
- Control of hazardous substance in E-waste
- Setting of targets for collection amounts in formal sectors
- Public/private partnerships
- Information exchange for technologies with other
countries
- Deposit and refund programs operated by managing
associations
- Cost for collection and recycling (or recovery)
- Levying of taxes for producers and importers

８６
 4.3.3 Capacity building on E-waste management through ESM

Environmentally Sound Management (ESM) for E-waste includes all possible

measures to protect human health and the environment from adverse effects that may occur

due to E-waste treatment. These measures can be delineated using policies and regulations,

technical guidelines, and capacity building for E-waste management. E-waste management

approaches based on the ESM principle have mainly been introduced by the Basel

Convention.

To achieve the management of E-waste based on ESM, the following strategic

approach was adopted in the Basel Convention (Basel Convention, 2020e):

a) Prevention and minimization of E-waste through the establishment of goals, both

intermediate and long-term, to reduce the quantity of waste of electrical and electronic

equipment destined to final sinks such as landfills.

b) Introduction of cleaner production approaches to minimize, and where feasible,

eliminate hazardous substances in electrical and electronic equipment and consequently their

wastes.

c) Achievement of ESM by promoting best available practices and the use of sound

recycling technologies adapted to national specificities, including the development of

appropriate measures for evaluation, testing, characterization, and classification of E-waste.

d) Promotion of information exchange and training through the establishment of

regional information collection and dissemination ‘clearing houses,’ including the

development of training curricula for trainers, to be accessible to all relevant stakeholders.

To adopt this approach, evaluation of E-waste systems must first occur by (1)

assessing existing management circumstances, (2) developing national inventories, (3)

８７
establishing mechanisms for information exchange at the national and regional levels, and (4)

monitoring E-waste.

Effective E-waste management needs to quantify the amount of waste by type,

characterize the waste stream, identify major sources of E-waste, and assess the risks

involved in the existing management system. If a proper E-waste inventory that notes sources

is conducted in a city/country, it can be used to predict trends in E-waste generation for future

years and help the responsible authorities become proactive in formulating national

regulations on how to handle the problem of E-waste treatment. Moreover, the inventory can

provide a basis to develop a framework and create infrastructure for investments from

manufacturing companies, allowing an approach for successful E-waste management to be

initiated, designed, and ultimately implemented. The inventory, which provides a baseline for

assessing progress and identifying challenges, should contain information such as the type of

e-waste and the amount of each type that is generated, collected, and recycled. This

categorical and quantitative information on E-waste can be used to inform the installation of

such waste treatment facilities, including those dealing with certain hazardous substances

such as refrigerants and heavy metals, by identifying necessary capacities of facilities.

Additionally, it can be used to inform the development and application of environmentally

sound technologies for managing E-waste.

4.3.4 Sustainable development of E-waste management with international

cooperation

Sustainable development means fulfilling the needs of the present while preserving

the needs of the future from social, economic and environmental points of view. For example,

the needs of the present in the field of E-waste management are mainly resources. E-waste

８８
contains precious metals such as gold and silver, which have high economic value and are in

demand, i.e., "needed", by the present population. The needs of the future are to ensure the

quality of the environment can be survivable, safe, and enjoyable. In the e-waste system, the

process of obtaining the needs of the present (resources) can lead to hazardous substances in

it to be released into the atmosphere, soil, and water, thus degrading the quality of the

environment for future generations. From this perspective, development of sustainable e-

waste management systems through establishment of proper policies and the development of

efficient technologies is important to meet the needs of the present and the future.

In some Asian countries including Bangladesh, solid waste recycling infrastructure is

lacking and insufficient for handling fast-growing E-waste. Thus, there is a limit to balancing

the treatment of E-waste and preserving resources for the needs of the future. This is because

improper treatment, such as open burning and acid leaching, commonly practiced in informal

sectors. Therefore, the collection of E-waste should be incrementally converted from informal

sectors to formal sectors, and proper treatment technology suitable for the characteristics of

E-waste must be introduced for the development of a sustainable E-waste management

system. However, the establishment of formal collection programs and proper treatment

technologies for E-waste requires extensive time and money, so it is difficult to simply apply

a system of formal collection and proper treatment technologies in some Asian countries.

In order to successfully develop sustainable E-waste recycling technologies, build

recycling facilities, and create a formal collection system for E-waste, partnerships with

various advanced countries or international organizations should be considered. International

partnerships can allow for sharing of E-waste management experiences and information

concerning its transboundary movement using field trips, technical seminars, technical

support, and transference of tools and equipment.

８９
 4.3.5 Raising awareness on E-waste management

Raising awareness of proper E-waste management in some Asian countries,

including Bangladesh, needs to be emphasized by establishing educational programs for the

public. In particular, programs should focus on why and for what purpose E-waste should be

managed. In many Asian countries, materials are recovered by improper methods during E-

waste treatment such as open burning or acid leaching. However, people who perform such

treatments are not aware of why these methods are dangerous, and they are more attracted to

the monetary value of the materials recovered as a result of their work. Therefore, people who

perform E-waste treatment often do not recognize health problems and environmental

pollution caused by hazardous substances in it.

Islam et al. (2016) surveyed households in Dhaka, Bangladesh on the awareness of

the adverse effects that E-waste has on human health and the environment. Results showed

that only 9% of households knew about the negative health and environmental impacts of

illegal E-waste treatments. Also, before the survey, 68% of respondents in Dhaka were

unaware of the meaning of E-waste (Islam et al., 2016).

For E-waste management in some Asian countries including Bangladesh, education

and training programs should be developed and implemented to increase awareness and

tailored for different level of ages, from children to seniors, are very important. Through

these programs, the public should become aware of the adverse effects on human health and

the environment from illegal or improper E-waste treatment in informal sectors. People may

be more receptive to these programs if it is also emphasized that valuable resources such as

gold or silver can be recovered obtained from E-waste through the best available recycling

technologies. These education and training programs should be prepared to provide user-

９０
friendly materials so that consumers or stakeholders can easily access necessary information

concerning E-waste management.

Nonetheless, illegal treatment businesses may hinder the setting up formal collection

facilities because illegal treatment businesses received a distorted subsidy by over-reporting

recycling amounts. The reality of informal recycling sites in Bangladesh is not transparent,

and related documentation is limited because illegal sites have been reluctant to participate in

the formal government-supported management system. Therefore, in some Asian countries

such as Bangladesh or Pakistan, it may be difficult to introduce education and training

programs to informal sectors of E-waste treatment. Partnerships between informal sectors and

local expert groups could be initiated to prepare programs and manuals for e-waste

management to prevent illegal or improper treatment.

９１
5 Sustainable management plan of E-waste in Bangladesh

5.1 Overview

Recently, the economic growth in Bangladesh triggered the advent of the market

selling electrical and electronic products for approximately 160 million people. End-of-life

electrical and electronic products turn into huge amounts of E-waste every day. Such a large

quantity of E-waste upon improper disposal resulted in tremendous environmental burdens in

Bangladesh. To solve the problems associated with E-waste management in Bangladesh, it is

important to understand the current situations and socio-economic infrastructures for E-waste

recycling.

This chapter deals with the introduction to Pre-EPR (Extended Producer Responsibility)

policy design and management system, roles and responsibility of stakeholders, public

awareness, and international cooperation for transfer of recycling technology and training

program. Recycling target rates and methods are discussed to effectively implement the

management plan. Finally, expected outcomes and benefits are included after the successful

implementation of Pre-EPR for E-waste management.

5.2 Suggestions for E-waste management in Bangladesh

5.2.1 Suggestions of E-waste management system

In order to properly manage E-waste in Bangladesh, it is suggested the approach

scheme with the Figure 5-1. The first step is to impose responsibility in the management of

E-waste to the stakeholders. In the imposition of responsibility on management of E-waste, it

is necessary to establish clearly the responsibility of stakeholders according to the E-waste

９２
management stages of production/sales, consumption/discharge, collection, and recycling.

The second step is to build a kind of association (managing body) composed with producers

and importers to manage -waste stream in major provinces. At this time, the association

(managing body) should be established and operated by producer/manufacturer, and the main

role of association is to enable E-waste to be collected in the formal sector (Authorized

recyclers; 7 companies by ECC). The association is a foundation that can be developed into a

Producer Responsibility Organization (PRO) in the future. The third step is to collect the

information such as E-waste generation and treatment through the producer/manufacturer

association and formal recyclers to develop an E-waste inventory in Bangladesh. The fourth

step is to properly process E-waste. In developing countries including Bangladesh, it is very

difficult to secure recycling technologies, facilities and budget to manage E-waste formally.

In order to solve these difficulties, it should establish partnerships both between informal

sectors and local experts and between developing countries and developed countries to

manage E-waste in an environmentally sound manner.

Furthermore, simple financial flows should be ensured. The cost of purchasing the

EEE by the consumer passes through the sales stage to the producer/manufacturer. The

producer/manufacturer pays the fee to the association, which is used for collection and

recycling costs in the formal sector. The government decides to give incentives to

producers/manufacturers using information collected through association.

In the overall E-waste management plan, the role of the government is crucial. The

government should carry out legislative activities in E-waste management, including methods

for collecting E-waste into the formal sector. It can be adopted to force

producer/manufacturer to collect E-waste with economic incentives.

９３
 Figure 5-1. Suggested E-waste management system in Bangladesh

5.2.2 Responsibilities and roles of stakeholders towards sustainable E-waste

management

For proper and sustainable system of E-waste management such as collection and

recycling, the responsibility and role of stakeholders should be clearly defined and

established, as shown in Table 5-1. Major stakeholders are included with government,

producers/manufacturers, association, consumers and recyclers. In order to divert informal

collection flow of E-waste, the government should establish a collection scheme in the

management system for fulfilling the roles of stakeholders in the process from E-waste

generation to final disposal. The government should carry out legislative activities with

producers/ manufacturers who fulfill the responsibility of E-waste management. In addition,

it is necessary to induce stakeholder participation in the conversion of E-waste collection into

the formal sector through public awareness. Responsibility of producers can be taken by

establishing a managing association to control their E-waste. The producers (i.e.,

manufacturers and importers) are to pay the fee on collection and recycling of E-waste to the

９４
managing association.

Main responsibilities of the managing association as Producer Responsibility

Organization (PRO) will be establishing and supporting collection systems in an efficient and

properly manner. The managing association must collect E-waste generated or imported by

their companies to be sent to an authorized recycler in Bangladesh. In addition, the managing

association must collect information on EEE shipments and sales amount from

producers/manufacturers and information on E-waste collection and recycling amount from

collectors and recyclers and report them to the government. Consumers should discharge to

prevent mixing of E-waste with municipal solid wastes through collection program trained by

some organizations under regulations. Recyclers should recycle properly in accordance with

the regulation related to waste management and ensure to use valuable materials from

collected wastes.

Table 5-1. Responsibilities and roles of stakeholders in E-waste management

Type Responsibilities and roles
Government - Legislative activity, economic incentives and penalty
- Setting up collection centers by the City Corporations and
Municipalities
- Prepare awareness building material and the program of public
awareness for E-waste management
Producers - Establish the managing association(PRO)
(manufacturers, - Pay collection and recycling cost to association
importers)
Consumers - Separate and discharge of E-waste from municipal solid wastes
- Participate at the program to collect E-wastes

Managing - Establishment and operation of collection system

association - E-waste sent to formal recycling sector
- Report on amount of E-waste collection and recycling to Government
Recyclers - E-waste recycling by environmentally sound manner
- Report on amount of E-waste recycling to the managing association

９５
 5.2.3 Establishment of collection system and its managing association

In developing countries, the most important aspect in E-waste management is formal

collection, but it is very difficult to change from informal collection to formal collection. In

order to change the collection system of E-waste, managing association or PRO should be

established initially by producers/manufacturer of electrical and electronic equipment in

major cities. The managing association can control E-waste collection through formal sectors

and prevents it from other municipal solid waste stream. In the managing association,

producers must participate directly or induce the participation of collectors (scrap dealers) in

the existing informal sector. Government should support to establish a managing association

with financial incentives such as tax exemption or subsidy. A small scale of the managing

association can be operated by the cost of collection and recycling from

producers/manufacturer and try to collect E-waste formally in major cities. Establishment of

the association as managing body of E-waste collection formally could be the most effective

approach method in developing countries. Even though it takes some time to establish the

collection system of E-waste in developing countries, the scheme of managing association

may be very helpful and beneficial to manage E-waste comprehensively in developing

countries from collection formally to recycling properly and treatment safely.

5.3 Introduction to Pre-EPR policy and system in Bangladesh

In order to develop sustainable E-waste management in Bangladesh, Pre-EPR

concept and policy has been explored by considering economic, social, and cultural contexts

of Bangladesh. This section describes the definition and concept of Pre-EPR, operating

system of Pre-EPR, the roles and responsibility of relevant stakeholders, establishment of

partnerships among stakeholders, and expected outcomes and benefits of Pre-EPR implement.

９６
 By adopting Pre-EPR policy and measures could help to improve E-waste recycling

in three ways.

First, they could help improve the implementation of a new E-waste rule, and he

integration of EPR into environmental and circular economy objectives (e.g., through wide

application of EPR to other products). This would contribute to reducing open burning and

landfilling of E-waste and recovering valuable resources from it.

Second, the Pre-EPR could financially support the formal sector under the

supervision of DOE. This could be developing clear responsibilities and roles between

stakeholders, ensuring cost contribution by producers, proper treatment by recyclers, and

transparency on the performance and material and financial flows.

Third, changes to the Pre-EPR could strengthen the financial incentives for collectors,

recyclers, and consumers in the formal sector. Appropriate economic incentives should be

developed to divert E-waste away from the informal sectors, flavoring into the formal sector

for proper treatment.

5.3.1 Definition and concept of Pre-EPR Policy

Extended Producer Responsibility (EPR) policy has been widely employed in many

countries, especially in EU, since 1990s. One of the major products that are commonly

managed by EPR is electronics. EPR involves producers (manufacturers, suppliers, retailers,

importers) taking extended responsibility for their products so that there is a direct incentive

for the design and manufacturing of environmentally conscious products that can be easily

recycled, and do not present significant environmental impacts upon disposal (Figure 5-2).

９７
 Figure 5-2. Concept of EPR policy

However, in many developing countries, such EPR policy are rarely adopted or

partly due to lack of legal framework, difference of cultural behaviors, and socio-economic

condition. Regular EPR (or full-fledged EPR) that is currently used for developed countries

may be inappropriate when directly adopted to developing countries and fail to implement.

Thus, more streamlined EPR system (or Pre-EPR) should be needed by considering current

situation and cultural contexts in Bangladesh. For example, E-waste in Bangladesh is

predominantly managed and treated by informal sectors, while such waste is commonly

recycled by the EPR system in developed countries, as shown in Figure 5-3.

Pre-EPR is the preliminary (simplified or streamlined) EPR policy before the full-

fledged (or regular EPR) that has been introduced in developed countries. Such Pre-EPR

takes a simple approach by considering limited resources and cultural contexts of Bangladesh.

Step by step approach to regular EPR will be taken over the years to come.

９８
 Figure 5-3. E-waste management by formal and informal sectors in developed and
developing countries

Figure 5-4 presents the step by step approach of Pre-EPR by several revisions

towards the full-fledged or full-scale EPR. Such approach includes the expansion of target E-

waste items, the increase of recycling target rates, incremental financial supports, and more

involvement of stakeholders.

Figure 5-4. Concepts of Pre-EPR and full-scale EPR

９９
 5.3.2 Objectives and Principles of Pre-EPR system

(1) Objectives

The objectives of Pre-EPR policy in Bangladesh include the design of material and

financial flows of sustainable E-waste management, the development of E-waste recycling

targets, the support of E-waste recycling by formal sectors, the establishment of partnership

among stakeholders, and the effective implementation of the proposed E-waste rule. As a

result, the system of sustainable E-waste management in Bangladesh by adopting Pre-EPR

policy is developed, based on social, economic, and cultural contexts. Figure 5-5 Presents the

objectives of Pre-EPR policy in Bangladesh.

Figure 5-5. Objectives of Pre-EPR policy for E-waste in Bangladesh

１００
 (2) Principles

For the environmentally sound management of E-waste in Bangladesh, fundamental

principles on E-waste management should be established. The principles on E-waste

management can be described by considering the recommendations made by a number of

developed and developing countries, including the Basel Convention and OECD.

(1) 3P’s (Polluter Pay Principle): Polluters (including producers and importers) must

bear the cost of managing the pollution to prevent damage to environment and human

health.

(2) Environmentally sound manner: All practicable steps to ensure that e-waste is

managed in a manner which will protect human health and the environment against the

adverse effects that may result from improper disposal of such waste.

(3) Sustainable development: The management of E-waste should be sustainable to

protect to the environment and human health. In order to properly manage E-waste,

experience sharing, information exchanges, and technical supports from developed

countries should be strongly encouraged.

(4) Environmental awareness by public and stakeholders: Awareness raising of E-

waste management should be developed by school education and training with easy

access for publics. Training and education programs should be developed for relevant

stakeholders to recognize their responsibilities for properly managing such waste.

5.3.3 Policy design for Pre-EPR system

In most developed countries, the Extended Producer Responsibility (EPR) policy is

commonly adopted to manage E-waste. Designing an EPR policy with clear and well-defined

roles is essential for all actors or stakeholders, including producers, consumers, authorities,

１０１
collectors, and recyclers. However, in Bangladesh, it is not easy to immediately introduce the

EPR system under their current circumstances due to lack of socio-economic infrastructures

to implement it for E-waste. Prior to the introduction of the full-scale or full-fledged EPR

system, therefore, it is necessary to take a simple and step-by-step approach for E-waste

management in Bangladesh through a small-scale demonstration project in specific regions

with the participation of stakeholders in preparing the policy design.

The policy design to manage E-waste in Bangladesh should be carried out according to

the 3P’s principle (i.e., Polluters Pay Principle) before adopting the EPR system. In the

management of e-waste, it is very important to identify the subject of ‘polluters’. “Polluters”

(i.e., usually producers) should have the responsibility to manage E-waste properly and to

prevent the adverse effects resulting from improper disposal of E-waste. Responsibility to

producers is mainly taken by achieving E-waste recycling target rates set by the DOE.

Penalties can be imposed to producers, if they do not meet the targets. Consumers can play a

significant role of collection and recycling of E-waste by source separation and returning it to

registered collectors and collection centers. Often times, producers can provide consumers

with economic incentives when they buy new electronics via take-back or exchange programs.

Collectors and processors must comply with the relevant environmental laws and regulations

to transport safely and to minimize contamination that may affect the surrounding

environment in the process of E-waste. In this way, the 3P's principle can be established by

identifying the 'polluters' related to E-waste management properly with performing

behavioral responsibilities.

The small-scale demonstration project can be adopted as Pre-EPR system as a preliminary

step for introducing the EPR system. The Pre-EPR system is an E-waste management process

as a means to partially convert the E-waste stream in the country from informal sectors to

formal sectors. In order to covert current E-waste streams into formal sectors, financial

１０２
mechanism in the management of collection and recycling of E-waste should be invented.

To financially support the collection and recycling of E-waste, Producer Responsibility

Organization (PRO) or a managing association is to be formed and consisted of producers

and importers who can establish the waste collection in major cities in Bangladesh. Once the

PRO is formed, producers and importers can pay their contribution cost or fee to the PRO, so

that they can use the fee to pay to collectors and recyclers.

Several issues in designing an effective Pre-EPR policy of E-waste have been identified

and discussed, including legal frameworks and regulation, system coverage, system financing,

producer responsibility and ensuring compliance. The implementation of Pre-EPR system is

slightly different from the EPR system in developed countries. The implementation methods

of Pre-EPR system in Bangladesh are shown in Table 5-2.

Table 5-2. The implementation methods of Pre-EPR policy

Pre-EPR system Method

Collection program - Control by the managing association with producers

Recycling
Regulatory approach
Voluntary industry practices
Financial mechanism
- Pay collection fee to collectors by PRO
Pay recycling fee to recyclers by PRO
- Support PRO by producers and importers, and E-waste
recycling association
- Control hazardous substance in E-waste
- Set recycling target rate for recycling in formal sectors
- Public/private partnership
- Information exchange for technologies with other
developed countries
- Cost contribution (levy taxes) by producers and
importers
- Financial supports and operation by PRO
- Subsidy for collectors and recyclers

１０３
 5.3.4 Proposed management system of E-waste by Pre-EPR

The Pre-EPR management system for E-waste in Bangladesh is shown in Figure 5-6.

Producers (i.e., manufacturers and importers) should annually collect and recycle their

assigned quantities corresponding to the mandatory recycling rate (kg/person year) notified

by the DOE/ MOEFCC based on annual sales data. Producers can fulfill their obligations by

joining to Producer Responsibility Organization (PRO) or by taking their individual

obligations by collecting and recycling E-waste via take-back/exchange program or deposit-

refund scheme. In the case of producers who join the PRO, they can fulfill the recycling

obligations by paying their contribution fee to the PRO. The cost of the contribution is

annually determined by the PRO under the supervision of government officials, based on

collection and recycling costs. The PRO provides the subsidies to the collectors and recyclers

to act on the producers’ obligations for collection and recycling. The collectors and recyclers

carry out collection and recycling operations with the subsidies received and usually contracts

with the PRO. Both the PRO and the association of recyclers should submit an annual report

on the collection and recycling performance directly to the DOE or other third party

authorized by the MOEFCC. Producers who fail to meet their recycling obligations will have

to pay a fine more than the recycling cost of E-waste. The Pre-EPR policy is designed for

establishing E-waste recycling in an environmentally sound manner by financially supporting

early-stage formal sector industry. There will be a competition of E-waste recycling between

formal sectors and informal sectors under the Pre-EPR system. Thus, the material flow of E-

waste into informal sectors should be discouraged by using economic incentives and

strengthened regulations in the Pre-EPR, diverted to formal sectors.

１０４
 Figure 5-6. Management system of E-waste by Pre-EPR in Bangladesh.

5.3.5 Role and responsibility of relevant stakeholders

In order to establish sustainable system of E-waste management such as collection

and recycling, the responsibility and role of stakeholders in the Pre-EPR system should be

clearly established. Roles and responsibility of each stakeholder are summarized in Table 5-3.

Major stakeholders include with government, producers, producer responsibility organization

(PRO) association, consumers, collection centers, and recyclers. In order to divert informal

collection of E-waste to formal sectors, the government should establish a collection scheme

in the management system by fulfilling the roles of stakeholders involved in the system. The

DOE needs to develop E-waste regulations based on the EPR policy, including recycling

target rates and penalty, recycling and treatment guidelines of E-waste, and permits for

recycling facilities. The government should carefully carry out legislative activities

communicating with producers who fulfill the responsibility of E-waste management. In

１０５
addition, it is necessary to induce stakeholder participation in the conversion of E-waste

collection into the formal sector through public awareness. Producers should take full

responsibility of E-waste for recycling, while consumers properly return E-waste to registered

collectors, sellers or collector centers. Collection centers properly store E-waste for reuse and

recycling and transfer it to authorized recycling facilities. Responsibilities for PRO include

the establishment of collection and recycling system for E-waste and to operate it properly.

The PRO for producers should support the collection and recycling of E-waste by providing

economic incentives to achieve national target rates of E-waste set by the government(i.e.,

DOE). In addition, the PRO must collect information on EEE shipments and sales amount

from producers (manufacturers and importers) and information on E-waste collection and

recycling amount from collectors and recyclers and report them to the government.

Consumers should properly dispose E-waste separate at source by preventing it from

municipal solid waste and involving collection programs operated by PRO and local

government under the Pre-EPR. Recyclers should properly process E-waste in accordance

with the regulation related to waste management and ensure to recover valuable materials

from collected E-waste.

１０６
 Table 5-3. Roles and responsibilities of stakeholders in Pre-EPR for E-waste

Stakeholders Role and responsibility

Bangladesh DOE ➢ Develop E-waste regulations and policy
➢ Issue permits/ECC and registration of collection, recycling,
and exports/imports
➢ Assign recycling target rates and penalty to producers
➢ Develop E-waste recycling guideline
Producers ➢ Support E-waste collection and facilitating reuse
(assemblers,
➢ Take full responsibility of E-waste including payment of
manufactures,
importers) contribution cost of collection and recycling
➢ Establish Producer Responsibility Organization (PRO) for
collection and recycling
➢ Report sales data to DOE
Sellers ➢ Safe collection of E-waste and sending it to collection center
Producer ➢ Establish operation of recycling system in formal sectors
responsibility
➢ Establishing a private or public collection center by private
organization (PRO)
investment or public-private partnership
➢ Submit report of recycling rates to DOE
➢ Raise public awareness
➢ Subsidize collection and recycling of formal sectors
Private/group ➢ Proper disposal and source separation from municipal solid waste
consumers
➢ Return E-waste to sellers or collection centers
Collection centers ➢ Safe E-waste collection, storage, and transport to recyclers
Reprocessors ➢ Collect E-waste generated during repair of electric/electronic
products and send them to the collection center
Recyclers ➢ Manage hazardous materials released from E-waste recycling
➢ Make safe storage and transport of E-waste
➢ Follow workers safety for harmful aspects of E-waste
Local government ➢ Supervise and monitor E-waste recycling of formal sectors
Note: The role and responsibility in bold are included in the proposed E-waste rules.

１０７
 5.3.6 Establishment of Producers and Recyclers Associations

In developing countries including Bangladesh, informal sectors dominantly collect E-

waste that is generated from municipalities. It is very difficult to change from informal

collection to formal collection. In order to divert current informal collection flow into the

formal flow, producer association (i.e., Producer Responsibility Organization, PRO) or

managing association should be established initially by producers of electrical and electronic

equipment under the Pre-EPR. The PRO manages and supports E-waste collection and

recycling by formal sectors and prevents it from municipal solid waste stream. In the Pre-

EPR system, producers must participate directly or induce the participation of collectors

(scrap dealers) in the existing informal sector. Government should support to establish the

PRO with financial incentives such as tax exemption or subsidy.

Recycling association of E-waste can be also formed by the support of DOE to

establish the recycling by formal sectors. Establishment of such associations as managing

body of E-waste collection by formal sectors is required for achieve national recycling target

rate. Even though it takes some time to establish such formal collection and recycling system

of E-waste in developing countries, the establishment of managing association may be very

helpful to properly manage E-waste comprehensively in developing countries from collection

formally to recycling properly and treatment safely.

１０８
 5.3.7 Recycling targets, cost contribution and penalty of E-waste: Example

(1) National recycling target rate

The national E-waste recycling target in Bangladesh can be calculated based on GDP,

socio-economic structure, and population. In 2018, the EU average rate of E-waste recycling

is 6.6 kg/person/year. In 2020, the national target rate of E-waste in South Korea is 7.0

kg/person/year. By considering the rates of E-waste recycling, the recycling target rate can be

calculated by the following example as below. It should be note that the national recycling

target rate should be increased over the time, as the Pre-EPR is steadily established and

continually developed.

National recycling target rate (1st year)

7.0 kg/person/yr x 160,000,000 (population of Bangladesh) x GDP ratio

(USD 1,700 Bangladesh/USD 31,000 Korea) x 0.1 (socio-economic structure)

= 6,160 ton /yr (1st year) (equivalent to 0.0385 kg/person/yr)

(2) Recycling target items

There are numerous electrical and electronic equipment that are used for households

and industry sectors. Lifespans of the equipment range from two or three years to more than

10 years, depending on the type of devices. TVs, mobile phones, and computer devices are

commonly found in e-waste streams. In EU, the recycling target items by WEEE directive

１０９
include a wide range of electrical and electronic equipment such as large and small household

appliances, IT and telecommunications equipment, consumer equipment, lighting equipment,

toys, leisure and sports equipment, medical devices, monitoring and control instruments, and

automatic dispensers. In South Korea, the current recycling target items in the EPR system

are similar to those of the WEEE Directive in EU, but fewer items. In 2003, the recycling

target items by the EPR started with TVs, refrigerators, washing machines, air conditioners,

and computers and continually expanded over the past 15 years.

In Bangladesh, recycling target item by the Pre-EPR system can start with TVs as a

starting point since consumers recently buy brand new digital TVs by active promotion by

retailers and manufacturers. The recycling target list can also be expanded to several devices

or equipment (e.g., such as refrigerators, washing machines, air conditioners, computers,

printers, and mobile phones), once the system is working properly and steadily operated. It

should be noted that the generation rates, collection scheme, and availability of recycling

facilities for the candidate recycling items should be carefully considered, before they are

listed in the recycling target items by the Pre-EPR.

１１０
１１１
 (3) Cost contribution by producers

The Pre-EPR financially supports collection and recycling of E-waste in formal

sectors from producers. In other words, producers take physical and financial responsibility

of e-waste collection and recycling in formal sectors in Bangladesh. The cost of collection

and recycling is covered by the contribution of supporting money from producers. The cost

can be estimated and calculated based on annual sales data of electronic products. The cost

contribution by producers is presented as an example, as following.

１１２
 (4) Penalty

Producers may pay more than the cost of recycling when they do not meet the target

rate set by the DOE. The cost of penalty can be calculated by using the recycling cost with

weighting factor (e.g., 1.5, or 2.0), which creates incentives for producers to meet the target

(Table 5-4).

１１３
 Table 5-4. Recycling unit cost and mass composition of E-waste (example)

Item Recycling unit Percent

cost (USD/ton ) Composition (%)
by mass
Refrigerators 200 5%
Washing machines 200 5%
Air conditioners 100 5%
TVs 500 50%
computers 500 20%
printers 500 5%
Copy machines 500 5%
Mobile phones 1,000 5%
Total 100%

The following calculation for penalty for producers by the DOE is provided as an

example. Such example can be modified by changing several factors (e.g., recycling target

rate, weighting factors, market share, mass composition, or unit cost) and assumptions, if

needed.

１１４
 5.3.8 Establishment of partnerships among stakeholders under Pre-EPR

A number of stakeholders involve the management of E-waste, including producers,

importers, retailers, consumers, collectors, recyclers, NGOs, and government. Without

communications and partnerships among the stakeholders, it would be difficult to establish

sound and sustainable management of E-waste. Especially, the majority of E-waste in

Bangladesh is collected and managed by informal sectors, which largely process the waste in

a rudimentary way, causing health risks to humans and environmental pollution due to

improper disposal. Meetings and association of representatives from each stakeholder are

necessary to build the communications and partnerships during the management of E-waste

in Bangladesh.

１１５
 Thus, in order to effectively implement the Pre-EPR system in Bangladesh, the

partnerships among the stakeholders should be established along with strategic approaches

based on environmentally sound management. The environmental sound management of E-

waste in Bangladesh can be achieved by promoting best available practices and the use of

appropriate recycling technologies adapted to local conditions, including the development of

measures for national recycling target rates and penalties, financial contribution by producers,

and technical supports from countries (e.g., Korea and Japan) with exporting electronics.

Training programs and technical guidelines for E-waste collectors and recyclers should be

provided by the DOE. Relevant information (e.g., E-waste flow, barriers to collection and

recycling, incentives, etc.) among the stakeholders is shared and exchanged for establishing

the management of Pre-EPR by formal sectors. Figure 5-7 presents the establishment of

partnerships among stakeholders under the Pre-EPR in Bangladesh.

Figure 5-7. Establishment of communication and partnerships among stakeholders by Pre-

EPR in Bangladesh

１１６
 5.3.9 Public awareness of E-waste by Pre-EPR system

According to a recent study (Isalm et al., 2016), more than 90% of the households

were unaware of the term “E-waste”. It indicates that public knowledge and environmental

awareness are relatively very low. Raising environmental awareness for public regarding the

source separation and proper disposal of E-waste would be necessary to establish collection

points and systems for the waste under the Pre-EPR. Education for public schools, pilot

projects, workshops, collection campaigns, advertisement on social media, newspapers, TV

and radio can be employed to raise the awareness. Local government can also play a

significant role in building awareness programs and establishing collections of E-waste.

5.3.10 Expected outcomes and benefits of Pre-EPR system

The following outcomes and benefits are expected when the Pre-EPR is successfully

implemented in Bangladesh.

(1) It would help to create separate collection systems and increase recycling of E-waste.

(2) It would reduce the quantity of E-waste commonly destined to final sinks such as

landfills by diverting informal sectors into formal sectors where proper recycling

processes are practices. It will recover valuable materials from E-waste in formal

sectors as high quality secondary raw materials by promoting the development of

resource markets towards a circular economy in Bangladesh.

(3) Technological and organizational progress in E-waste management can be made with

the technical support of advanced countries such as Korea and Japan.

１１７
 (4) Ultimately, it would contribute to resource security by recovering valuable resources

from E-waste.

The Pre-EPR policy is designed for establishing E-waste recycling in an environmentally

sound manner by financially supporting early-stage formal sector industry. There will be a

competition of E-waste recycling between the formal sectors and the informal sector under

the Pre-EPR system. Thus, the material flow of E-waste into the informal sector should be

discouraged by using economic incentives and strengthened regulations in the Pre-EPR,

flowing into the formal sector. The management of E-waste should be sustainable to protect

to the environment and human health. In order to properly manage E-waste, sharing of

experiences, information exchanges, and technical supports from advanced countries, such as

Korea and Japan are also strongly encouraged by international cooperation.

It should also be noted that the Pre-EPR does not function in a vacuum, and other policy

instruments such as incentives or disposal fee of E-waste, voluntary agreements with industry,

awareness campaigns and education should be accompanied. Responsible activities of source

separation and product choices by consumers are also crucial.

According to the waste management hierarchy, reduce and reuse is more preferred

options than recycling and treatment. For this reason, the Pre-EPR system does not interfere

any actions related to reuse or prevention. Reuse and prevention activities for consumers and

citizens are also strongly encouraged by the government since the Pre-EPR plays an

important role of recycling and treatment.

１１８
 5.4 International cooperation on E-waste recycling technology and training

program

In order to develop appropriate recycling technology as well as to build recycling

facilities of E-waste, partnership with various developed countries or international

organization should be considered. Partnerships can include sharing experiences of E-waste

management and transboundary movement, such as field trips, technical seminars, technical

support and transfer of tools and equipment. The implementation of such partnerships can

enhance capacity building for E-waste management at a relatively low cost and time.

For sustainable management of E-waste, it is important to make policies by EPR

scheme and other various policy tools. In the previous section, the policy design for E-waste

management was suggested by Pre-EPR scheme. In this policy making, appropriate recycling

technology and training program should be developed to improve awareness of peoples

related to E-waste management and to settle a new system. Wilson et al. (2012) assessed

implementation of waste management system in 20 cities and found that the stakeholder

could not properly implemented the waste management system if information on that system

was not provided by the authorities, or if the stakeholder did not have the appropriate

knowledge or ability(Wilson et al., 2012). In this way, it is very important to develop

recycling technology and training programs according to the level of manufacturers and

assemblers, consumers, recyclers, refurbishers, collection centers and others.

5.4.1 Applications of appropriate E-waste recycling technology by international

cooperation

In most developing countries including Bangladesh, E-waste is handled in informal

sector by monetary appeal. In informal sector, safety measures for workers are ignored, and

１１９
as E-waste is recycled in open place, it may cause pollution in surrounding environment.

Therefore, for the safety and sustainable management of E-waste, it is necessary to develop

and apply appropriate recycling technologies, which must be able to minimize the

environmental pollution and adverse effect on human health. The development of technology

for appropriate recycling technology of E-waste can be separated into the stages of collection,

pre-treatment, and material recovery.

- Collection: Collection is most important stage in converting E-waste stream from

informal sector to formal sector.

- Pre-treatment: Pre-treatment is to separate a specific component from E-waste or to

make it to a state for material recovery, which may include size reduction by mechanical

methods, manual separation and others.

- Material recovery: The material recovery is a stage of recovering substances such as

gold, silver, copper, aluminum and others from products discharged from the pre-treatment

stage through chemical and thermal methods.

(1) Options for E-waste collection methods

In the stage of collection, E-waste should be separated from other municipal solid

waste streams to build a collection system for the improvement of resource recovery and the

removal of hazardous substances. In the EU, the manufacturer has been responsible for

collecting E-waste in accordance with the WEEE Directive, and policies in Korea and Japan

have been developed to make the collection of E-waste mandatory for producers and retailers.

The collection system of E-waste can be performed by take-back system or exchange

program, door to door system and municipal collection, and these system are summarized in

１２０
Table 5-5. The take-back system is a method that returns E-waste to a producer or retailer

when a consumer purchases a new product (UNEP, 2012). E-waste collection is performed

when new products are delivered or installed, and is generally operated free. In the door to

door system, consumers make a request to producer or Producer Responsibility Organization

(PRO) for collection of E-waste, and this is not limited to the case where the consumer must

purchase a new product (StEP, 2009). In the municipal collection, consumers can discharge

E-waste at specific date after paying a fee to a local government or installed a collection box

at specific site by a local government and PRO (UNEP, 2012).

Table 5-5. Typical collection system of E-waste

Methods
Take-back system or
Exchange Program
Door to Door system
Municipal collection
Description
- E-waste is collected by retailers or producers when
consumers purchase new products.
- Even if the consumer does not purchase a new
product, E-waste is collected by producers or
agencies such as PRO ,if requested
- E-waste collection cost is paid to the local
government by the consumer, or PRO installs a
separate collection box.

(2) Options for pre-treatment methods

Pre-treatment applies physical techniques to liberate and upgrade desirable materials

into relatively homogeneous streams, which are used as inputs for stage of material recovery.

The most common automatic pre-processing method is mechanical size reduction and

sequential sorting, while human labor is widely used for non-destructive disassembly.

Comparatively, manual dismantling achieves higher liberation rates without breaking the

original form of components and materials, which is easier to sort and improves re-usability.

１２１
Selective dismantling and mechanical separation can be optimally combined to have the most

cost-effective liberation result under certain economic conditions.

Also, pre-treatment is the operation of removing hazardous materials (refrigerants,

etc.) from E-waste and recovering substances that are relatively easy to decompose. For

example, for recycling of refrigerators and air conditioners, refrigerant must be recovered

separately before crushing. In addition, the parts containing mercury and its compounds must

be recovered from waste such as LCDs. Pre-treatment includes technologies such as manual

dismantling, shredding/comminution, and mechanical separation/enrichment, and the benefit

and issue of these technologies are shown in Table 5-6.

Table 5-6. Benefit and issue of pre-treatment of E-waste

Type Benefit Issue
Dismantling - Removal of hazardous materials - Hard to dismantle newer complex
(e.g. refrigerant) technologies
- less dust issue - Time-consuming
- Higher grade material for - Higher spending on labor and
end-processing transportation cost
- increased risk of public health and
safety.
Shredding/ - Faster automated systems - High dust issue
Comminution - reduced risk of public health and - Loss of material (up to 40%) as
safety dust
- increased throughput - Decreased grade for subsequent
- less volume for transportation. operation.
Mechanical - Faster automated system - Higher capital investment
separation/ - Reduced public health and safety - Not suitable for small recycling
Enrichment issue businesses
- increased throughput - Dust issue with dry systems
- Lesser mass/volume to transport - Moisture removal issue for wet
for final process systems.
- less energy intensive

１２２
 (3) Options for material recovery methods

The stage of material recovery is the final stage to refine and detoxify various outputs

liberated from the stage of pre-treatment, through chemical, thermal and metallurgical

processes to upgrade materials and reduce impurities as well as final disposal. A wide

spectrum of materials contained in E-waste demands diverse and separate treatment processes

and considerable investment in advanced technologies (especially metallurgical recovery) is

required to reach high recovery rate and low environmental impact. For instance, a typical

aluminum smelter in Europe requires a minimum input of 50,000 tons of aluminum scrap per

year to run a plant, and the investment cost is approximately 25 million Euro. For precious

metal refinery, there are only a few companies in the world equipped with technical know-

how, sophisticated flow sheets and sufficient economy of scale (e.g. Boliden in Sweden,

DOWA in Japan, Umicore in Belgium), which can fulfill the technical and environmental

requirements. For instance, the integrated smelter-refinery of Umicore Precious Metal

Refining in Belgium has the capacity of producing 2400 tons of silver, 100 tons of gold, 25

tons of palladium and 25 tons of platinum per year (investment cost on the metallurgical

processes was more than 500 million Euro) (Schluep et al., 2009). Recently, metallurgical

recovery improves metal recovery by a combination of pyro-metallurgy and hydro-metallurgy,

and further development of technology by bio-metallurgy is in progress. The benefit and

issue of such metallurgical recovery are shown in Table 5-7.

１２３
 Table 5-7. Benefit and issue of material recovery of E-waste

Type Benefit Issue

Pyro-metallurgy - Higher/faster reaction rates due to - High energy requirement
high temperature - Generation of dioxins, furans and
- Easier separation of valuable and volatile metals
waste. - Loss of iron and aluminum in slag
- Recovery of plastics is not possible
Hydro- - More accurate, predictable, - Slow, time-consuming,
metallurgy easily controlled, - Requirement of fine grinding for
- Less energy intensive efficient leaching,
- More chemicals required, high
toxicity,
- High reagent consumption
Bio-metallurgy - Low operating cost, - Slower process
- Reduction in chemical usage, - Not fully developed for the higher
- Easier handling of waste metal complexity of electronic
water/effluent waste.

(4) Application of appropriate recycling technology of E-waste Management

At the stage of collection-pre-treatment-material recovery of E-waste, appropriate

recycling base for E-waste can be established by combining various technology options.

Wang et al. (2012) conducted a scenario study for sustainable E-waste treatment in

developing countries. By Wang et al. (2012) study, E-waste treatment technology was divided

into pre-processing and end-processing to derive an application method of treatment

technology that can be effectively accessed in developing countries. These results indicate

that manual dismantling is selected for pre-processing in the initial stage of introduction of

treatment technology, and end-processing can provide an appropriate treatment technology

base for E-waste through a combination of global infrastructure. This suggests that

developing countries have limitations in the immediate application of advanced recycling

technologies for economic and industrial reasons, and propose to switch to advanced

technologies such as mechanical separation over time (Wang et al., 2012).

１２４
 Therefore, in developing countries such as Bangladesh, for the development of

appropriate recycling technology and the installation and operation of facilities, the collection

infrastructure of E-waste must be prepared so that E-waste can flow into the authorized

facilities. In the pre-treatment process of E-waste, measures to ensure worker safety must be

prepared, and international cooperation such as a global partnership for advanced recycling of

e-waste must be carried out.

An example of an international partnership for E-waste management is a capability

enhancement project conducted by (HUST) in Vietnam and KOICA in Korea. In this project,

in order to train expert for E-waste management in Vietnam, as shown in Figure 5-8, a

research facility such as the support of practical equipment was established at HUST

(KOICA, 2013). The implementation of these partnerships can enhance the capacity building

and the collection program for E-waste management at a relatively low cost and time.

Figure 5-8. Partnership between Vietnam and Korea

5.4.2 Training program of E-waste management

The development of training programs is one of the means for effective

implementation of E-waste management system. Training program should include methods to

manage E-waste while minimizing its impact on human health and the environment. In

１２５
addition, training programs should be developed according to the classification of

stakeholders for E-waste management. For example, training programs for manufacturers

should include a description of legal obligations for E-waste management and ways to

implement them, and training programs for consumers explain how to discharge E-waste.

These training programs should be simple and clear. About 32% of people in Dhaka,

Bangladesh know the terminology of E-waste. Therefore, in order for the stakeholder to

properly implement the system based on the EPR scheme, it must be prepared by cartoon,

photo, voice guidance and others for easy understanding (Islam et al., 2016).

Also, training programs should be easily accessible to stakeholder. There are ways to

use the most popular mass media in Bangladesh, and to provide briefing sessions or lectures

so that the stakeholder can easily access the training programs. The method of using the mass

media should allow the stakeholder to view information or data of the training program on E-

waste management through a web site, installation and distribution of brochures, placards,

banners, etc. in public place, TV and newspaper ads and others. A separate briefing session or

lecture is held at the local government or school, and enables stakeholder participation.

Table 5-8 briefly shows the composition of the training materials of E-waste. In general,

the training manual describes the characteristics of E-waste, human health and environmental

impact, and legal basis in common. Regarding the characteristics of E-waste, the importance

of management such as the amount generated and the value as a resource is mentioned. About

human health and environmental effects, it describes the adverse effects of hazardous

substances such as heavy metals. The legal basis explains the E-waste related laws in each

country. The matters other than the common ones mainly describe the responsibility to be

fulfilled for each stakeholder and how to implement them. Although the name and scope of

the stakeholder set by law may differ slightly by country, training manuals are usually

１２６
prepared according to the classification of manufacturer/producer, retailer/seller, consumer,

collector, and dismantler/recycler.

Table 5-8. Composition of general training materials

Table of contents in training materials
Characteristics of E-waste
Impacts on human health and environment
Legal basis
Divided into Producers/ Responsibility of retailer/seller
stakeholders Manufacturers/ How to fulfill responsibilities
importers (e.g. establishment of PRO, etc.)
Performance reporting
Retailers Responsibility of retailer/seller
/Sellers Methods on storage and transportation of E-waste
Performance reporting
Consumers/ Responsibility of consumer/mass consumer
Mass E-waste discharge method
consumers (e.g. Take-back system, etc.)
Collectors Responsibility of collector
Methods on storage and transportation of E-waste
Performance reporting
Dismantlers Responsibility of dismantler/recycler
/ Dismantling guide by E-waste type
Recyclers Handling and storage of output material from
dismantling
Safety measures
Performance reporting

Figure 5-9 is a web site with information on training programs prepared in Malaysia,

India and Ghana (DOE Malaysia, 2020; Meity India, 2020; GIZ, 2019). Web site in Malaysia

and India provide information through materials on training program or brochures according

１２７
to the classification of stakeholders such as manufacturer, consumer, dealer and others. In

addition, it describes the date, participation methods and others for E-waste training program.

For E-waste handler, there is training manual in Ghana (See Figure 2(c)). Even though this

manual does not cover whole handing methods of E-waste in detail, safety equipment, safe

disassembly and others in E-waste treatment are explained with flowchart and pictures.

(a) Case in Malaysia

(b) Case in India

(c) Case in Ghana

Figure 5-9. Examples of training programs for E -waste in other countries

１２８
6 Conclusions and Recommendations

6.1 Summary and conclusions

Based on the results of this research project, the key findings are summarized. Throughout
the report the importance of recognizing the roles and shared responsibilities of producers,
collectors and recyclers in life cycle of electronic products has been emphasized. This report
also highlights the analysis of Extended Producer Responsibility (EPR) system commonly
adopted by developed countries, focusing on the development of sustainable management
plan of E-waste in Bangladesh by considering local conditions and economic and socio-
infrastructure.

(1) Issues and problems related to E-waste management: Several issues and
problems of concern related to E-waste management in Bangladesh include
severe environmental pollution, toxic hazards to recyclers in informal sectors,
loss of recoverable resource, and lack of legal frame and environmental
awareness for public.

(2) Analysis of the existing legal framework and regulation: The draft Hazardous
Waste (E-waste) Management Rules 2019 is waiting for final approval after the
inter-ministerial meeting. In the legal frame and regulations, there are still lack of
detailed target recycling rates for producers, mechanism of financial and material
flows, economic incentives and penalties, and detailed implementation methods
and strategy.

(3) Summary of international efforts on E-waste in other countries: Many

developed countries adopted EPR systems for E-waste collection and recycling
with target goals and economic incentives. Producer Responsibility Organization
is commonly formed to take a joint responsibility for producers and financially
support collectors and recyclers. Full or partial responsibility and role of each
stakeholder in the full life cycle of electronic products is clearly stated upon E-
waste recycling.

１２９
 (4) Development of sustainable management plan of E-waste in Bangladesh:
The sustainable management plan of E-waste in Bangladesh emphasized pre-
EPR system with national target rated of recycling for limited number of target
electronic devices, financial and material flows, the roles and responsibility of
stakeholders, the establishment of effective partnerships and environmental
awareness by consumers. This study suggests that there is a need for
collaboration with the formal sectors and the DOE. The DOE should work more
closely with the sectors to solve the E-waste disposal problems.

6.2 Recommendations

In additions to the key findings, the following recommendations are made based on the
results of this study.

(1) Understand and communicate how the Pre-EPR works as a part of E-waste
management plan. The DOE should understand how the Pre-EPR works and
interacts with other policy initiatives, such as E-waste import ban and Basel
Convention, and the potential benefits it can bring.

(2) Establish Pre-EPR system with limited recycling target items. Pre-EPR
system should be initially established for supporting E-waste recycling by the
formal sector with national recycling target rates. It is then followed by full-scale
EPR as the system is properly operated along with expanded target recycling
items and increased recycling target rates of E-waste.

(3) Setting-up national recycling target rates under the Pre-EPR system with
limited items. TVs and other electrical and electronic devices (e.g., refrigerators,
washing machines, or mobile phones) are recommended for recycling target
items under the Pre-EPR system. Recycling target rate of E-waste can be
annually evaluated with socio-economic infrastructure. The streamlined
approach with limited target items would give more insight into the formulations
of the target rates, leading to the establishment of Producer Responsibility
Organization (PRO) and association of E-waste recyclers with joint work plan.

１３０
 (4) Establish partnership, coordination and governance among stakeholders:
Upon the establishment of Pre-EPR system, partnerships, coordination, and
governance among the stakeholders (i.e., producers, collectors, recyclers, NGO,
consumers, government, PRO) would be crucial with clear roles and
responsibility for E-waste collection and recycling. PRO and association of e-
waste recyclers from the formal sector should be established to compete the
informal sectors and take the responsibility for the national recycling target rate.

(5) Communicate with stakeholders with clear responsibility under the Pre-
EPR system. The DOE should communicate their responsibilities with
stakeholders clearly under the Pre-EPR. and emphasize that each stakeholder
should play an important role of E-waste collection and recycling.

6.3 Limitations and future directions

In additions to the recommendations, the following limitations and future directions are made
based on the results of this study.

(1) Limited field observations and communications: This study is based on

available literature review and field observations into existing E-waste recycling
by EPR schemes in a variety of countries. Although local experts have been
involved in the development of E-waste management plan in Bangladesh, more
field investigations are still needed to reflect current challenges and efforts on E-
waste recycling in Bangladesh.

(2) Lack of comprehensive and reliable research database on E-waste: There is a

lack of comprehensive and reliable research database on E-waste management in
Bangladesh through research on literature, analysis of statistics, and
communication with local experts.

(3) Effective Pre-EPR system in new E-waste rule: Since new E-waste rule is
being prepared by the DOE, effective Pre-EPR system can be combined and
employed in the new rule. By adopting the system, collection and recycling
activities in the formal sector can be steadily formed and supported by PRO.

１３１
(4) Establishment of PRO and association of recyclers: In order to divert current
informal flow into the formal flow, producer association (i.e., Producer
Responsibility Organization, PRO) and association of recyclers in the formal
sector should be initially established to take responsibility for collection and
recycling of E-waste under the Pre-EPR system. Producers can fulfill their
obligations by joining to the PRO by cost contribution for collecting and
recycling E-waste, while recyclers can process it for material recovery in an
environmentally sound manner.

(5) Evaluation of Pre-EPR system: Pre-EPR system can be initiated as a

demonstration project in Dhaka City with the formal sector. The DOE could
capitalize its access to international expertise and share this with recyclers from
the formal sector by collaboration. The DOE has already been working closely
with the formal sector to support E-waste recycling. The Pre-EPR can be further
developed and applied to other areas in Bangladesh by evaluating its
effectiveness and identifying potential barriers to be overcome.

１３２
References

Alam, M., Bahauddin, K.M., 2015. Electronic waste in Bangladesh: evaluating the situation,
legislation and policy and way forward with strategy and approach. Present
Environment and Sustainable Development 9(1), 81-101.

Alam, T., Shams, S., Yahya, S.M., Ishtiak, M.A., 2013. Assessment of E-waste management
in Dhaka City: Issues and Strategies Towards Sustainable Development.
International conference on Environmental and Hazardous Substance Management
towards Green Economy, May 21-23, 2013, Bangkok, Thailand.

Alcántara-Concepción, V., Gavilán-García, A., Gavilán-García, I.C., 2016. Environmental

impacts at the end of life of computers and their management alternatives in México.
Journal of Cleaner Production 131, 615-628.
Awasthi, A.K., Zeng, X., Li, J., 2016. Relationship between E-waste recycling and human
health risk in India: a critical review. Environ. Sci. Pollut. Res. Int. 23, 11509-11532.
Awasthi, A.K., Li, J., 2017. Management of electrical and electronic waste: A comparative
evaluation of China and India. Renewable and Sustainable Energy Reviews. 76. 434-
447.
Awasthi, A.K., 2018. E-waste management in India: A mini-review. Waste Management &
Research. 36(5). 408-414.
Baidya, R., Dednath, B., Ghosh, S.K., Rhee, S.W., 2020. Supply chain analysis of E-waste
processing plants in developing countries. Waste Management & Research. 38(2). 173-
183.
Baldé, C.P., Forti V., Gray, V., Kuehr, R., Stegmann, P., 2017. The Global E-waste Monitor
– 2017, United Nations University (UNU), International Telecommunication Union
(ITU) & International Solid Waste Association (ISWA), Bonn/Geneva/Vienna.
Baldé, C.P., Wang, F., Kuehr, R., Huisman, J., 2017. The global e-waste monitor 2017:
Quantities, flows and resources.
Basel Convention, 2017. Revised draft factsheets on specific waste streams.
Basel Convention, 2018. Draft practical manuals on Extended Producer Responsibility and
on financing systems for environmentally sound management.
Basel Convention, 2020a. PACE, Pilot projects, Jordan,
http://www.basel.int/Implementation/TechnicalAssistance/Partnerships/PACE/Pilotproj
ects/tabid/5381/Default.aspx (access date: 25 June 2020).

１３３
Basel Convention, 2020b E-waste,
http://www.basel.int/Implementation/Ewaste/Overview/tabid/4063/Default.aspx
(access date: May. 19, 2020).
Basel Convention, 2020c. Practical manuals on promoting the environmentally sound
management wastes,
http://www.basel.int/Implementation/CountryLedInitiative/EnvironmentallySoundMan
agement/ESMToolkit/Practicalmanuals/tabid/5847/Default.aspx (access date: May. 29,
2020).
Basel Convention, 2020d. National Reports,
http://www.basel.int/Countries/NationalReporting/NationalReports/BC2018Reports/ta
bid/8202/Default.aspx (access date: May. 29, 2020).
Basel Convention, 2020e. Environmentally Sound management of used electrical and
electronic equipment (E-waste) in Asia-Pacific,
http://www.basel.int/Portals/4/Basel%20Convention/docs/pub/leaflets/leaflet01012011
-1.pdf (access date: July 3, 2020).
Bogaert, S., Acoleyen, M.V., Tomme, I.V., Smet, L.D., Fleet, D., Salado, R., 2008. Study on
RoHS and WEEE Directives N 30-CE-0095296/00-09.
Brigden, K., 2005. Recycling of electronic wastes in China and India: workplace and
environmental contamination.
http://www.greenpeace.org/raw/content/china/en/press/reports/recycling-of-electronic-
wastes.pdf.
California Department of Resources Recycling and Recovery (CalRecycle), 2020.
https://www.calrecycle.ca.gov/electronics/retailer (access date: March. 05, 2020).
Cao, J., Lu, B., Chen, Y., Zhang, X., Zhai, G., Zhou G., Jiang, B. and Schnoor, J.L., 2016.
Extended producer responsibility system in China improves E-waste recycling:
Government policies, enterprise, and public awareness, Renewable and Sustainable
Energy Reviews 62, 882-894.
CEC, 2016. Quantitative Characterization of Domestic and Transboundary Flows ofUsed
Electronic Products. Case Study: Used Computers and Monitors in NorthAmerica.
Commission for Environmental Cooperation, Montreal, Canada.
Center for Environment and Resource Management (CERM), 2019. Draft version of
Assessment of generation of e-waste, its impacts in environment and resource

recovery potential in Bangladesh.

１３４
Center for Policy Dialogue (CPD), 2007. Bangladesh Vision 2021.

Chaudhary, K., Vrat, P., 2018. Case study analysis of E-waste management systems in
Germany, Switzerland, Japan and India. Benchmarking, An International Journal.
Chen, L., Yu, C.N., Shen, C.F., Zhang, C.K., Liu, L., Shen, K.L., Tang, X.J., Chen, Y.X.,
2010. Study on adverse impact of E-waste disassembly on surface sediment in East
China by chemical analysis and bioassays. Journal of Soils Sediments, 10, 359-367.
China Household Electric Appliance Research Institute (CHEARI), 2013. White paper on
WEEE recycling industry in China.
Choi, Y., Rhee, S., 2017. Evaluation of energy consumption in the mercury treatment of
phosphor powder from spent fluorescent lamps using a thermal process. Sustainability,
9(11).
Chowdhury, F., 2014. Assessment of electronic waste management systems in Dhaka city.
Master Thesis, Bangladesh University of Engineering and Technology, Dhaka,
Bangladesh.

Clemett, A., 2006. A review of environmental policy and legislation in Bangladesh,

Department for International Development, Final Research Report Section 2. 1-13,
United Kingdom.

Cruz-Sotelo, S.E., Ojeda-Benitez, S., Sesma, J.J., Velázquez-Victorica, K.I., Santillán-Soto,

M., Garcia-Cueto, O.R., Concepción, V.A., Alcántara, C., 2017. E-waste supply chain
in mexico: Challenges and opportunities for sustainable management, Sustainability
9(4) 503.
Cucchiella, F., D’Adamo, I., Koh, S.L., Rosa, P., 2015. Recycling of WEEEs: An economic
assessment of present and future e-waste streams. Renewable and Sustainable Energy
Reviews 51, 263-272.
Government of China, 2020. Administrative measure on Tax Levy and use for E-waste
recycling, http://www.gov.cn/gzdt/2012-05/30/content_2149195.htm. (access date:
April 29, 2020).
Debnath, B., Roychoudhuri, R., Ghosh, S.K., 2016. E-waste Management – A Potential
Route to Green Computing, Procedia Environmental Sciences, 35, 669-675.
Electronics Recycling Coordination Clearinghouse (ERCC), 2020. Map of States with
Legislation https://www.ecycleclearinghouse.org/contentpage.aspx?pageid=10 (access
date: March. 02, 2020).

１３５
Environment and Social Development Organization (ESDO), 2010. E-waste: The
Bangladesh Situation, Dhaka, Bangladesh.

Environment and Social Development Organization (ESDO), 2012. Guidelines for E-waste
Management in Bangladesh.

Environment and Social Development Organization (ESDO), 2014. Magnitude of the Flow
of E-waste in Bangladesh.

ESDO, 2010. E-waste: Bangladesh situation. Study Report Environment and Social
Development Organization-Environmental and Social Development Organisation
Dhaka. Bangladesh.
European Union, 2002. EU Directive: 2002/96/EC of the European Parliament and of the
Council of27 January 2003 on the restriction of the use of certain hazardous substances
(RoHS) in waste electrical and electronic equipment. Off. J. L037, 0019e0023.
European Union, 2012. EU Directive: 2012/19/EU of the European parliament and of the
council of 4 July 2012 on waste electrical and electronic equipment (WEEE). Off. J.
L197/38.
European Union, 2015. EU Directive: 2015/863 of 31 March 2015 amending Annex II to
Directive 2011/65/EU of the European Parliament and of the Council as regards the list
of restricted substances. Off. J. L137/10.
Forti, V., B, Baldé, C.P., Gray, Kuehr, R., Bel, G., 2020. The Global E-waste Monitor –
2020, United Nations University (UNU), International Telecommunication Union (ITU)
& International Solid Waste Association (ISWA), Bonn/Geneva/Vienna.
Garlapati, V.K., 2016. E-waste in India and developed countries: Management, recycling,
business and biotechnological initiatives. Renewable and Sustainable Energy Reviews
54, 874-881.
General Economic Division, 2020. Making Vision 2041 a Reality: PERSPECTIVE PLAN
OF BANGLADESH 2021-2041, Bangladesh Planning Commision, Ministry of
Planning, Government of the People’s Republic of Bangladesh.
Ghosh, S.K., Debnath, B., Baidya, R., De, D., Li, j., Ghosh, S.K., Zheng, L., Awasthi, A.K.,
Liubarskaia, M.A., Ogola J.S., Tavares, A.N. 2016. Waste electrical and electronic
equipment management and Basel Convention compliance in Brazil, Russia, India,
China and South Africa (BRICS) nations. Waste Management and Research. 34(8).
693-707.

１３６
Ghosh, S, K. Interim Report on “E-waste management under legal framework in India and
learning points for Bangladesh e-waste management policies,” 2020.

Golev, A., Schmeda-Lopez, D.R., Smart, S.K., Corder, G.D., McFarland, E.W., 2016.
Where next on e-waste in Australia? Waste Management 58, 348-358.
He, W., Li, G., Ma, X., Wang, H., Huang, J., Xu, M., Huang, C., 2006. WEEE recovery
strategies and the WEEE treatment status in China, Journal of Hazardous Materials,
B136, 502-512.
Heeks, R., Subramanian, L., Jones, C., 2015. Understanding E-waste Management in
Developing Countries: strategies, Determinants, and Policy Implications in the Indian
ICT Sector. Inf. Technol. Dev. 21, 653-667.
Herat, S., Pariatamby, A., 2012. E-waste: a problem or an opportunity? Review of issues,
challenges and solutions in Asian countries, Waste Management & Research. 30, 1113-
1129.
Hotta, Y., Hayashi, S., Bengtsson, M., Mori, H., 2009. Extended Producer Responsibility
Policy in East Asia in consideration of International Resource Circulation. Institute for
Global Environmental Strategies (IGES).
Ikhlayel, M., 2017. Environmental impacts and benefits of state-of-the-art technologies for
E-waste management. Waste Management 68, 458-474.
Ikhlayel, M., 2018. An integrated approach to establish E-waste management systems for
developing countries. Journal of Cleaner Production, 170, 119-130.
Islam, Md. T., Abdullah, A. B., Shahir, S. A., Kalam, M. A., Masjuki, H. H., Shumon, R.,
and Rashid, Md. H. 2016. A public survey on knowledge, awareness, attitude and
willingness to pay for WEEE management: Case study in Bangladesh, Journal of
Cleaner Production 137, 728-740.

Islam, S., Ahmed, K., Masunaga, S., 2015. Potential ecological risk of hazardous elements
in different land-use urban soils of Bangladesh. Science of the Total Environment 512,
94-102.

Jang, Y. C., 2010. Waste electrical and electronic equipment (WEEE) management in Korea:
generation, collection, and recycling systems. Journal of Material Cycles and Waste
Management, 12(4), 283-294.

Kahhat, R., Kim, J., Xu, M., Allenby, B., Williams, E., Zhang, P., 2008. Exploring E-waste

１３７
 management systems in the United States. Resources, Conservation and Recycling, 52,
955-964.
Karim, R.T., Bari, N., Amin, M.A., 2014. E-waste Management in Bangladesh, 2nd
International Conference on Green Energy and Technology. IEEE, 104-109.

Kojima, M., Yoshida, A., Sasaki, S., 2009. Difficulties in applying extended producer
responsibility policies in developing countries: case studies in e-waste recycling in
China and Thailand. Journal of Material Cycles and Waste Management 11, 263-269.
Korea Resources Circulation Service Agency (KORA), 2020. Statistics & Archives,
http://www.kora.or.kr/eng/products/packingRecyclingTotal.do (access date : Mar.03,
2020).
Kristensen, E., Lindblad, B., Mortensen, J., 2011. The WEEE Directive & Extended
Producer Responsibility: Lost in Transposition, Roskilde University–ENSPAC–
TekSam–K1–Fall.
Kumar, A., Holuszko, M., Espinosa, D.C.R., 2017. E-waste: an overview on generation,
collection, legislation and recycling practices. Resources, Conservation and Recycling
122, 32-42.
Lee, S.C., Na, S.I., 2010. E-waste Recycling Systems and Sound Circulative Economies in
East Asia: A Comparative Analysis of Systems in Japan, South Korea, China and
Taiwan. Sustainability, 2(6), 1632-1644.
Li, J. and Zhao, N., 2010. Controlling transboundary movement of waste electrical and
electronic equipment by developing international standards, Environmental
Engineering Sciences, 27(1), 3-11.
Lu, C.Y., Zhang, L., Zhong, Y.G., Ren, W.X., Tobias, M., Mu, Z.L., Ma, Z.X., Geng, Y.,
Xue, B., 2015. An overview of E-waste management in China. Journal of Material
Cycles and Waste Management, 17, 1-12.
Manomaivibool, P., 2009. Extended producer responsibility in a non-OECD context: the
management of waste electrical and electronic equipment in India. Resource
Conservation and Recycling 53(3) 136–144.
Masud, M.H., Akram, W., Ahmed, A., Ananno, A.A., Mourshed, M., Hasan, M., Joardder,
M.U.H., 2019. Towards the effective E-waste management in Bangladesh: a review,
Environmental Science and Pollution Research, 26, 1250-1276.
McCartor and Nash, Reducing lead poisoning among children in Kathgora, Bangladesh,
Pure Earth, EU, UNIDO, and USAID, 2019.

１３８
Miller, T.R., Duan, H., Gregory, J., Kahhat, R., Kirchain, R., 2016. Quantifying domestic
used electronics flows using a combination of material flow methodologies: A US case
study. Environmental Science & Technology 50, 5711-5719.
Ministry of Commerce of the People’s Republic of China (MOFCOM), 2020. Measure for
the Implementation of “Old for New” policy for home appliance,
http://www.mofcom.gov.cn/article/b/g/201008/20100807062260.shtml. (Access date:
April 29, 2020).
Ministry of Environment and Forest (MOEF), East Pakistan Water Pollution Control
Ordinance, East Pakistan Ord. No. V., Government of East Pakistan, Dhaka, 1970.

Ministry of Environment and Forest (MOEF), Environmental Pollution Control Ordinance,

Ordinance no. XIII of 1977, Dhaka, 1977.

Ministry of Environment and Forest (MOEF), National Environmental Policy, Dhaka, 1992.

Ministry of Environment and Forest (MOEF), National Environmental Management Action

Plan (NEMAP) Volume II: Main Report, Dhaka, 1995a.

Ministry of Environment and Forest (MOEF), The Bangladesh Environmental Conservation

Act, Act No. 1 of 1995., Dhaka, 1995b.

Ministry of Environment and Forest (MOEF), Environmental Conservation Rules, Dhaka,

1995.

Ministry of Environment and Forest (MOEF), The Environmental Court Act, Dhaka, 2000.

Ministry of Environment and Forest (MOEF), Medical Waste (management and processing)
Rules, Dhaka, 2008.

Ministry of Environment and Forest (MOEF), Hazardous Waste (E-Waste) Management

Rules (Draft), Dhaka, 2019.

Ministry of Environment and Forest (MOEF), 3R(Reduce,Reuse,Recycle) Strategy of

Bangladesh.

Ministry of Environment and Forests India, E-Waste (Management and Handling) Rules,

New Delhi, 2011.

Ministry of Environment, Forests and Climate Change India, E-Waste (Management) Rules,

１３９
 New Delhi, 2016.

Ministry of Environment, Forests and Climate Change India, E-Waste (Management) Rules,
amended in 2018, New Delhi, 2018.

Ministry of Environment, Forest and Climate Change, Gvernment of India (MOEFCC),

2016. E-Waste (Management) Rules, 2016, http://moef.gov.in/g-s-r-338-e-23-03-2016-
E-waste-management-rules-2016/ (access date: July 14, 2020).
Ministry of Environment, Japan (MOE Japan), 2005. Japan’s Experience in promotion of
the 3Rs for the establishment of a sound material-cycle society (2005).
Ministry of Environment, Japan (MOE Japan), 2020. Home Appliance Recycling
Act ,https://www.env.go.jp/recycle/kaden/law.html (access date: March 04, 2020).
Ministry of Internal Affairs and Communication, Japan (MIC Japan), 2020.
https://www.soumu.go.jp/main_sosiki/hyouka/hyouka_kansi_n/ketsuka_nendo/h29.ht
ml (access date: March 04, 2020).
Ministry of Environment, Korea (MoE Korea), 2003. 2003 White paper of Environment.
Ministry of Environment, Korea (MoE Korea), 2019a. 2019 White paper of Environment.
Ministry of Environment, Korea (MoE Korea), 2019b. Obligation rate of packing materials
and product (Notice No. 2019 – 266).
Ministry of Environment, Korea (MoE Korea), 2020. Environmental laws,
http://me.go.kr/home/web/law/list.do (access date: Feb 03, 2020).
Mott Macdonald, 2018. Final report on analysis of current e-waste management scenario in
Bangladesh: Feasibility & project structuring study for E-waste management facility
for Hi-Tech park authority. The World Bank Group.

OECD, 2016. Extended Producer Responsibility Updated Guidance for Efficient Waste
Management.
Osibanjo, O., Nnorom, I., 2007. The challenge of electronic waste (e-waste) management in
developing countries. Waste Management & Research 25, 489-501.
Pariatamby, A., Victor, D., 2013. Policy trends of E-waste management in Asia. Journal of
Material Cycles and Waste Management, 15, 411-419.
Park, H.S., Rhee, S.W., 2016. Estimation of retorted phosphor powder from spent
fluorescent lamps by thermal process. Waste Management, 50, 257-263.
Peralta, G.L., Fontanos, P.M., 2006. E-waste issues and measures in the Philippines, Journal
of Material Cycles and Waste Management, 8, 34-39.

１４０
Pure Earth, 2019. Project Completion Report: Reducing Lead Poisoning Among Children in
Kathgora, Bangladesh, 1-12.
(https://www.pureearth.org/wp-content/uploads/2019/10/PCR-Report_Kathgora.pdf)
Recupel, 2019. Together we close the loop, annual report 2019.
Rhee, S.W., 2016. Beneficial use practice of E-wastes in Republic of Korea. Procedia
Environmental Sciences, 31 707-714.
Rhee, S.W., Choi, H.J., Choi, Y., 2018. Resources Circulation of E-wastes in Korea
(Republic of), 13th International Conference on Waste Management and Technology
(ICWMT 13), Beijing, China.
Rhee, S.W, Choi, H.J., Park, H.S., 2014, Characteristics of mercury emission from linear
type of spent fluorescent lamp. Waste Management, 34(6), 1066-1071.
Rhee, S.W., 2017. Estimation of mercury amount in the components of spent U-type lamp.
Environmental Technology, 38(10), 1305-1312.
Roman, G, Desarrollo de un Programa Modelo para el Manejo de Residuos Electrónicos en
México. 2007.
http://www.inecc.gob.mx/descargas/sqre/2007_inf_plan_manejo_grm.pdf.
Schnoor, J.L., 2012. Extended producer responsibility for e-waste. ACS Publications.
Schumacher, K. A., 2016. Electronic waste management in the U.S. practice and policy, Ph.
D. Dissertation, University of Delaware, U.S.
Secretariat of Environment and Natural Resources (SEMARNAT), 2016. Mexican Official
Norm NOM-161-SEMARNAT-2011.
http://www.profepa.gob.mx/innovaportal/file/6633/1/nom-161-semarnat-2011.pdf.
Singh, N., Li, J., Zeng, X., 2016. Global responses for recycling waste CRTs in e-waste.
Waste Management 57, 187-197.
Solving the E-waste Problem (StEP), 2018. Developing Legislative Principles for E-waste
policy in developing and emerging countries.
Tarawneh, A., Saidan, M., 2013 Households Awareness, Behaviors, and Willingness to
Participate in E-waste Management in Jordan, International Journal of Ecosystem 3(5),
124-131.
Terazono, A., 2018. Revision of Waste Management Act and Basel Act in Japan and case
study of TBM data analysis, 5th Basel Forum, Beijing, China, March 24.
Tran, H.P., Wang, F., Dewulf, J., Huynh, T.-H., Schaubroeck, T., 2016. Estimation of the
unregistered inflow of electrical and electronic equipment to a domestic market: a case

１４１
 study on televisions in Vietnam. Environmental Science & Technology 50, 2424-2433.
Tue, N.M., Sudaryanto, A., Minh, T.B., Isobe, T., Takahashi, S., Viet, P.H., Tanabe, S., 2010.
Accumulation of polychlorinated biphenyls and brominated flame retardants in breast
milk from women living in Vietnamese e-waste recycling sites. Science of the Total
Environment 408, 2155-2162.
UNEP, 2020. Basel Convention on the control of transboundary movements of hazardous
wastes and their disposal.
United States Environmental Protection Agency (USEPA), 1989. Risk Assessment
Guidance for Superfund. Volume I: Human Health Evaluation Manual (Part A)
Interim Final. EPA/540/1-89/002.
US EPA, 2020. Wastes, Regulations/Standards,
https://web.archive.org/web/20150814064208/http://www.epa.gov/epawaste/conserve/
materials/ecycling/rules.htm (accessed date: Feb 27, 2020).
Wath, S.B., Vaidya, A.N., Dutt, P.S., Chakrabarti, T., 2010. A roadmap for development of
sustainable E-waste management system in India, Science of the Total Environment
409, 19-32.
Wang, H., Han, M., Yang, S., Chen, Y., Liu, Q., Ke, S., 2011. Urinary heavy metal levels
and relevant factors among people exposed to e-waste dismantling. Environment
International 37, 80-85.
Widmer, R., Oswald-Krapf, H., Sinha-Khetriwal, S., 2005. Global perspectives on E-waste,
Journal of Environmental Impact Assessment Review 25(5), 436–458.
Wilson, D.C., Rodic L., Scheinberg, A., 2012. Comparative analysis of solid waste
management in 20 cities. Waste Management & Research, 30(3), 237-254.
WorldBank, 2020. Data - GDP growth (annual %) - Bangladesh, (Access date: 2020.9.11.)
https://data.worldbank.org/indicator/NY.GDP.MKTP.KD.ZG?locations=BD.
Yang, J., Lu, B. and Xu, C., 2008. WEEE flow and mitigating measures in China, Waste
Management 28, 1589-1597.
Yousuf, T.B., Reza, A., 2011. E-waste management in Bangladesh: Present Trend and
Future Implication. Proceedings of 2011 World Congress of International Solid Waste
Association (ISWA), October 17-20, 2011, EXCO Daegu, Korea.

Zeng, X., Li, J.H., Stevels, A.L.N., Liu, L., 2013. Perspective of electronic waste
management in China based on a legislation comparison between China and the EU,
Journal of Cleaner Production 51, 80-87.

１４２
Zheng, J., Luo, X.-J., Yuan, J.-G., He, L.-Y., Zhou, Y.-H., Luo, Y., Chen, S.-J., Mai, B.-X.,
Yang, Z.-Y., 2011. Heavy metals in hair of residents in an e-waste recycling area,
South China: contents and assessment of bodily state. Archives of Environmental
Contamination and Toxicology 61, 696-703.
Zhou, L and, Xu, Z., 2012. Response to waste electrical and electronic equipments in China:
legislation, recycling system, and advanced integrated process, Environmental Science
& Technology 46 (9), 4713-4724.

１４３