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Australian Government
Department of Climate Change, Energy, the Environment and Water
Consultation: Regulation for small electrical products and solar photovoltaic systems
Submitted online via https://consult.dcceew.gov.au/regulation-small-electrical-products-solar-pv
21 July 2023
Australian Digital Inclusion Alliance submission to the Regulation for small electrical products and solar photovoltaic systems consultation
Thank you for the opportunity to provide this submission. The Australian Digital Inclusion Alliance (ADIA) welcomes the Government’s consideration of a proposed regulatory approach to e-stewardship. Specifically, our submission addresses the second of two categories of electrical/ electronic-products (e-products) under consideration: small electrical and electronic equipment (SEEE).
The state of digital inclusion in Australia
According to the latest Australian Digital Inclusion Index Data (ADII), 9.4% of the Australian population is highly digitally excluded, and 14.2% is digitally excluded. Taken together, almost one quarter of Australians remain digitally excluded. Additionally, an increasing number of Australians are reliant on mobile devices in order to access the internet and complete a range of digital tasks and activities necessary in contemporary society. 10.5% of Australians are mobile-only users, however, specific cohorts are significantly over-represented when it comes to mobile-only use, including people in very remote areas (32.6%), First Nations people (21.3%), and those on the lowest incomes (20.7%). We also know that mobile-only use brings with it additional challenges, including limiting a person’s capacity to improve their digital ability.
The relevance of product stewardship to digital inclusion
Digital inclusion is a multifaceted challenge. One aspect is affordable access to devices. In our highly digitised society, this is fundamental to being able to participate in all kinds of activities; from access to Government services, to banking, telehealth, studying and finding or undertaking employment.
We acknowledge that access to an appropriate device isn’t a holistic solution, rather one part of the digital inclusion challenge. Importantly, device access must be paired with the digital capability to purposefully use it, along with access to an affordable internet connection.
When it comes to small electrical and electronic equipment (SEEE), we note that the proposed scheme’s scope is designed to provide support for Australia’s transition to a circular economy. With the issue of access to an appropriate and affordable device sitting at the intersection of digital inclusion and the circular economy, there is an opportunity to amplify the positive digital inclusion outcomes of device re-use.
A 2023 study published by Back Market indicated that:
Refurbished smartphones and tablets always avoid a significant amount of environmental damage when compared to brand new smartphones and tablets.
Refurbished laptops and desktops almost always avoid a significant amount of environmental damage when compared to brand new, except when significant part replacements are required, like hard disks.
Furthermore, a Boston Consulting Group study found that the overall IT business could eliminate up to 15% of all global emissions by 2030 if it embraces the circular economy.
Challenges and opportunities
Donation of government and enterprise devices
We understand that Australian Government departments have a large number of devices that could have a big impact on device re-use and affordability. It is estimated that the Federal Government refreshes devices on a five-year cycle which sees over 3 million laptops, desktops and tablets and more than 2 million mobile phones taken out of service.
In addition, it is estimated that over a five-year period, approximately 10 million desktops, laptops and tablets and a further 6.5 million mobiles will be refreshed by the corporate and public sector.
Incentivising the donation of devices, securely erased and refurbished for re-use where appropriate, would bring great benefits to the number of Australians who lack access to an affordable and appropriate device.
We note that the proposed design of the scheme will improve recycling outcomes for e-waste collected outside of the scheme’s disposal services (for example, e-waste collected from large businesses and government agencies by commercial service providers), and we encourage the Government to consider incentivising device donation for the purpose of digital inclusion from such entities.
Existing e-stewardship schemes
At present, current e-stewardship schemes in Australia, including the National Television and Computer Recycling Scheme (NTCRS) and Mobile Muster, do not incentivise device donation for re-use. In 2021, the Productivity Commission released its Right to Repair Inquiry Report which noted that while product stewardship schemes such as the NTCRS have had success in terms of recycling and environmental impact, the current design of such schemes may be generating adverse incentives that limit their capacity to provide net benefits to the community:
‘The NTCRS was designed to be a recycling scheme only, with minimal incentives for co-regulatory bodies to repair and re-use collected e-waste. This results in some otherwise functional or repairable products being dismantled and destroyed for their component materials, rather than being put to higher-valued uses. re-use of e-waste would help to extend product lifetimes and potentially lead to better environmental outcomes than recycling.’
The Right to Repair Inquiry Report recommended that re-use be included within NTCRS annual recycling targets. This would allow NTCRS co-regulatory bodies to determine the best outcome for collected e-waste, instead of requiring all of it to be recycled. It also suggested that any future product stewardship schemes should include repair and re-use as options within their targets, where practical.
Incorporating device donation into the proposed scheme
We acknowledge and support that the proposed regulatory approach will have a focus on reducing waste and encouraging repair and re-use. However, there is an opportunity to increase digital inclusion outcomes alongside benefits to the circular economy by expanding the Targets and Obligations for the SEEE scheme to include device donation and re-use.
The latter two points from the discussion paper, included below, acknowledge both re-use and repair; but could go further in incentivising a re-use pathway for devices such a mobile phones, laptops and tablets that includes donation, refurbishment and redeployment for the benefit of digitally excluded individuals.
6.2 Targets and Obligations
The proposed scheme is anticipated to have 5 categories of targets and obligations for SEEE.
These include a target or obligation for:
how much e-waste must be recycled each year
the proportion of materials from recycled products that must be recovered for remanufacture (to maximise the material from recycled products is captured and used in manufacturing of new goods)
accessible drop-off services available to the public
maximising re-use of in-scope products where practical
educating and raising awareness about re-use and repair, how to keep in-scope products out of the waste stream as long as practicable and how to choose more sustainable products.
Incentivising device re-use presents huge opportunities to address the challenges of both digital exclusion and environmental impact. With rapid technological advancement and uptake, along with ever-present environmental concern, the ADIA will support advocacy around device re-use to realise such opportunities.
Yours faithfully,
David Spriggs
CEO, Infoxchange
Chair, Australian Digital Inclusion Alliance
Ishtar Vij
Director, Eloquium Group
Convenor, Australian Digital Inclusion Alliance
About the ADIA
The Australian Digital Inclusion Alliance (ADIA) is a shared initiative with over 500 business, government, academic and community organisations working together to accelerate action on digital inclusion. Our member organisations conduct a variety of research and practical programs aimed at reducing the digital divide and enabling greater social and economic participation for all Australians. The ADIA is supported by Infoxchange, Google and Telstra. Australia Post was also a founding partner.
The ADIA’s vision is to build a digitally inclusive Australia where everyone is equipped to fully participate in the economy and society. Being digitally included means a person has:
Affordable access to quality internet and appropriate devices.
Access to inclusively designed online content, that’s readable and accessible, including if they are differently abled or from culturally or linguistically diverse backgrounds.
The knowledge, ability, skills and confidence to complete tasks safely and securely online.
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