Memorandum by Hewlett-Packard
WASTE REDUCTION, ECO-DESIGN AND SUSTAINABLE PROCUREMENT
INTRODUCTION
1. Hewlett-Packard (HP) is pleased to have
the opportunity to make a submission to the House of Lords Science
and Technology Committee Inquiry into waste reduction and welcomes
the Committee's interest in this important area of environmental
policy.
2. HP believes that sustainable development
is not an option but an imperative. Environmental responsibility
is an integral part of our offering and we are willing and able
to differentiate ourselves in the market through our environmental
responsibility programmes.
3. Our biggest environmental impact is through
our products. As a result, HP developed its Design for Environment
program over 10 years ago with the goal of reducing the environmental
impact of products and services. In addition to meeting safety
and regulatory requirements, our objective is to design products
that use fewer materials, are more energy efficient, easier to
recycle and therefore create less waste, while maximising overall
value for our customers.
4. This commitment to environmental best
practice leaves HP well-placed to respond to the questions raised
by the Committee in relation to waste reduction. However, we recognise
that this is a broad and complex issue. As a result we have focused
our submission on two areas—sustainable procurement and
individual producer responsibility—where we believe that
the public sector has the power to make a lasting impact by incentivising
manufacturers to reduce waste in their products and production
processes.
EXECUTIVE SUMMARY
Sustainable Public Procurement
5. With a procurement budget of £1.5
billion, the UK public sector has the power to drive the market
for more sustainable products and services. HP strongly believes
the Government should reflect its commitment to environmental
sustainability and waste reduction in its approach to public procurement.
6. By adopting this approach, the Government
would provide an economic incentive for producers to develop products
and practices with a lower environmental impact and provide market
recognition for innovators such as HP.
Individual Producer Responsibility
7. The principle of individual producer
responsibility—where producers are responsible for the take-back
and disposal of their own products at the end-of-life—is
recognised as an important tool in encouraging the consideration
of end-of-life management at the stage of product design.
8. Individual Producer Responsibility provides
a competitive incentive for producers to design their products
so that they are easier and therefore cheaper to recycle.
9. Collective producer responsibility—where
all producers are jointly responsible for the recycling of all
products, including the products sold in the future—does
not provide an incentive to a producer to design products to be
easier to recycle.
10. Within the EU, 10 Member States (Bulgaria,
Denmark, Finland, France, Greece, Latvia, Portugal, Slovenia,
Spain, UK) have failed either to transpose or implement the Individual
Producer Responsibility provisions (Article 8.2) of the Waste
Electrical and Electronic Equipment Directive (WEEE Directive).
11. As a result the incentive to encourage
producers to focus on design for recycling is absent. This jeopardises
the attainment of the Directive's objectives.
Business Framework: Does the current policy, regulatory
and legal framework support and incentivise the development of
better, more sustainable products and processes? How is this framework
communicated to businesses and what is the level of awareness
and understanding among businesses?
12. The European WEEE (Waste from Electrical
and Electronic Equipment) Directive aims to stop the growing volume
of electrical and electronic waste disposed of in landfill sites,
by making manufacturers responsible for financing the recycling
of end-of-life equipment.
13. Article 8.2 of the WEEE Directive establishes
individual producer responsibility for the recycling of products
put on the market after 13 August 2005. Individual Producer Responsibility
(IPR) is a policy tool that provides incentives to producers for
taking responsibility of the entire lifecycle of his/her own products,
including end of life. Making each producer responsible for financing
the end-of-life costs of their own-branded products enables end-of-life
costs to be fed back to the individual producer. By modifications
to the product design, the producer can directly influence the
end of life cost.
14. Therefore individual producer responsibility
is recognised as an important tool in encouraging producers to
have regard to the end-of-life management of their products at
the stage of product design. Individual Producer Responsibility
provides a competitive incentive for producers to design their
products so that they are easier and therefore cheaper to recycle.
15. Analysis has shown that 10 Member States
(Bulgaria, Denmark, Finland, France, Greece, Latvia, Portugal,
Slovenia, Spain, UK) have omitted the requirements of Article
8.2 in transposing the WEEE Directive into their national law.
Instead, the legislation in these countries makes producers jointly
responsible for the recycling of future products, making it impossible
to implement individual producer responsibility. Another four
Member States (Austria, Germany, Hungary, Poland) have only partially
transposed the requirements of Article 8.2.
16. Without Individual Producer Responsibility
these incentives for design improvements are lost. Producers are
not rewarded for making their producers easier to recycle as the
end of life costs are related to market share of sales rather
than the costs of end of life management of producer's products.
17. The EC Treaty obliges each Member State
to implement the WEEE Directive in such a way as to give full
effect, in legislation and in practice, to the wording, object
and purpose of the WEEE Directive and not to put in place any
measure that would jeopardise the attainment of the Directive's
objectives. It is therefore crucial that the EU institutions and
the Member States ensure that individual producer responsibility
of Article 8.2 is correctly transposed and implemented in national
legislation.
The WEEE Directive states that:
"The establishment, by this Directive, of
producer responsibility is one of the means of encouraging the
design and production of electrical and electronic equipment which
take into full account and facilitate their repair, possible upgrading,
reuse, disassembly, and recycling."
"In order to give maximum effect to the
concept of producer responsibility, each producer should be responsible
for financing the management of the waste from his own products."
Business Framework: How central is sustainable
design to business thinking? What initiatives are in place to
encourage this and are they meeting business needs?
18. As one of the world's largest IT companies,
HP's greatest impact on the environment is through our products.
HP is committed to providing products and services that are environmentally
sound throughout their life cycles. Environmental impacts occur
at every stage of the product life cycle: from product design,
through manufacturing and transport, to use by customers and,
finally, disposal at the end of a product's life.
19. Managing these impacts is a complex
challenge as well as an opportunity. We apply design expertise
to create innovative products and services with reduced environmental
impact. This aligns with our customers' expectations of high performance,
low cost and minimum environmental impact, and provides HP a potential
source of competitive advantage. For example, flat panel displays,
notebooks, multi-function handhelds and all-in-one printers use
less material and are more energy-efficient than the desktop PCs
and individual scan, fax, copy and print devices they replace
for many customers. These newer products help reduce energy consumption,
CO2 emissions and space used in transport, all of which result
in lower environmental impact. HP ensures environmental design
does not compromise other product requirements such as quality,
reliability and price.
HP'S ENVIRONMENTAL
INITIATIVES
Design for the Environment (DfE)
—
HP was a pioneer in developing a DfE program in 1992.
Our DfE priorities are: energy efficiency, design for ease of
recycling, and materials innovation.
—
Many HP products carry Eco-labels, such as ENERGY
STAR, Blue Angel, Taiwan Green Mark, TCO, Canada Environmental
Choice, China Energy Conservation Program, IT-Eco Declaration
and PC Green Label.
—
61 business PCs, notebooks, workstations and monitors
registered with the U.S. EPA's Electronic Products Environmental
Assessment Tool (EPEAT) for public sector green procurement, including
the industry's first Gold-level notebook.
—
Environmental product stewards are integrated into
product design and R&D teams throughout HP to identify, prioritise
and recommend environmental design innovations.
Materials Reduction and Innovation
—
Materials reduction helps HP reduce costs, decrease
a product's environmental footprint, meet customer demands for
smaller/more efficient products, and reduce recycling/disposal
costs.
—
The DeskJet 3740 is one of a series of printers developed
on a single platform and sharing common parts. This platform is
projected to reduce materials use by more than 26,000 pounds over
four years.
—
Several years ago, we removed polyvinyl chloride
(PVC) from the case plastics of HP products, and we eliminated
the use of two brominated flame retardants (BFR's), PBB and PBDE,
and removed the remaining BFR's from the plastic housings of the
majority of our products. HP eliminated all BFRs—including
tetrabromobisphenol-A from external case parts of new HP brand
products introduced after 31 December 2006.
—
HP Office Recycled brand paper contains 30 per cent
post-consumer recycled paper fibre. In 2005, HP launched 100 per
cent post-consumer office recycled paper in Europe.
Packaging
—
HP packaging innovations reduce materials used and
increase the percent of recycled content. HP eliminates the use
of heavy metals in packaging materials, and reduces the weight
of packaging materials to decrease fuel consumption in transport.
—
Using high-density polyethylene for some camera packaging
reduced unused space by 25 per cent, increased quantity shipped
per pallet by 50 per cent and cut packaging materials use in half.
—
HP uses up to 85 per cent post-consumer recycled
content in external HP LaserJet print cartridge packaging and
up to 100 per cent post-consumer recycled content in external
HP inkjet print cartridge packaging.
Design for Reuse and Recycling
—
HP designs products that are easier to disassemble
and recycle. Features include: modular design so components can
be removed, upgraded, replaced and sorted for recycling; eliminating
glues/adhesives by using snap-in features; reducing the number
and types of materials used; using single plastic polymers; using
moulded-in colours and finishes instead of paint, coatings or
plating.
—
Many HP DeskJet printers are designed without paint,
plating and flame retardants, and use a snap-fit design and limited
number of screws, for easy disassembly and recycling.
—
The average number of parts in monochrome HP LaserJet
print cartridges has been reduced by more than half and the average
number of plastic resins by more than two-thirds.
—
In 2005, more than 7.8 million pounds (3,500 tonnes)
of plastics were recovered and recycled into material that has
been used to make new HP products as well as plastic trays, clothes
hangers, shoe soles and wire spools. A new application using recycled
cartridge plastics to make roof tiles was introduced in the European
market in 2005.
—
HP's DfR standards integrate clear design guidelines
and checklists into every product's design process to assess and
improve a product's recyclability. This allows HP to develop products
that are easier to recycle.
Next Steps
—
Continue to provide customers with the best value
and experiences through quality, environmentally-responsible products,
Research and develop new and innovative ways to "close the
loop".
—
Having recycled approximately half of billion kilograms
(one billion pounds) of electronics since 1987, HP has set a new
goal for another half billion kilograms by the end of 2010.
Government Policy: What is and should be the role
of the Government in addressing the issue of waste?
20. Government has two roles in addressing
the issue of waste. The first is the standard regulatory one,
already highlighted in relation to the WEEE Directive. Here it
is the Government's responsibility to transpose or set regulations
which encourage the reduction of waste.
21. However, the Government also has the
opportunity to use the power of the £1.25 billion public
sector procurement budget to drive the market for more sustainable
products. By reflecting its environmental priorities in its purchasing,
the Government could provide a powerful economic incentive for
producers to develop products and practices with a lower environmental
impact.
22. Through our experience in this area,
including our membership of the Government's Sustainable Procurement
Taskforce, HP has developed four principles which we believe should
guide the Government's approach to sustainable procurement.
Best practice
—
HP has worked with governments and international
bodies to develop workable environmental standards which can be
used as the basis of sustainable procurement policies. It is important
that the UK Government does not seek to "reinvent the wheel"
when developing its preferred approach but instead seeks to adopt
best practice from existing schemes operating elsewhere.
—
There are numerous environmental labelling schemes
in the global marketplace for IT products and for consumer products
in general, such as Energy Star or Blue Angel. However, many of
these schemes have different environmental criteria and measurement
methodologies. This means that, in order to obtain accreditation
from the different labels, the products of global companies, such
as HP, have to go through rigorous testing procedures several
times in order to meet the criteria for the differing national
and regional standards. HP therefore supports the general harmonisation
of the various labelling schemes for IT products, particularly
in relation to the criteria and the testing methodologies.
"Best Value" vs "Total Cost of
Ownership"
—
While HP believes it is vital that environmental
and sustainability factors become an important element of the
public procurement process, we recognise that value for money
principles will continue to be a priority for procurement officials.
—
It is therefore important that sustainable procurement
guidelines are based on "total cost of ownership" measures
in terms of costs, energy usage, reliability and recyclability
at end of life rather than simple "headline" costs.
Procurement decision-makers must be encouraged to prioritise long-term
environmental and efficiency criteria ahead of short-term cost
saving.
Implementation
—
In order for any procurement guidelines to be effective
they must be rigorously enforced. At present, even mandatory environmental
procurement criteria, such as the Market Transformation Programme's
"Quick Wins" are not consistently applied by public
sector procurement decision makers who are driven by stringent
efficiency targets to overlook environmental criteria and prioritise
lowest upfront costs.
Dialogue with manufacturers
—
HP believes that dialogue with IT manufacturers is
essential to ensure that the Government has a clear understanding
of market dynamics in particular sectors and that the sustainable
procurement programme has realistic goals and expectations.
—
HP believes that a formalised structure should be
developed which ensures accurate and timely industry input into
the Government's sustainable procurement programme and has offered
support to government ministers and officials in driving forward
this recommendation.
Government Policy: What lessons can be learnt
from other countries—within the EU and globally?
Sustainable Procurement
23. HP has, for some time, been in discussions
with both the Department for Environment, Food and Rural Affairs
and the Environment Agency about potential criteria for sustainable
procurement policies. Both of these organisations have shown particular
interest in the IT ECO declaration programme which was set up
by IT manufacturers in response to increasing interest from public
bodies in the Nordic region about the environmental attributes
of products. HP was instrumental in the development of the resulting
programme which allows participating manufacturers to communicate
environmental information in a set format whilst self-verifying
the data.
24. HP has also participated in the development
and implementation of sustainable procurement guidelines by many
of its major customers (including governments) across the globe.
In the United States HP has recently worked with a range of environmental
stakeholders including NGOs and the Environmental Protection Agency
on the development of the Electronic Products Environmental Assessment
Tool (EPEAT). The resulting programme helps inform procurement
officials about the environmental attributes of personal computing
devices based on a "total cost of ownership" assessment.
In the United States, the success of the EPA EPEAT is a best practice
example of how procurement officials can purchase IT products
with their environmental attributes in mind.
25. Industry-led self-declaration systems,
such as the IT ECO declaration, tend to be more workable than
externally imposed standards, which risk being arbitrary and unfairly
benefit one supplier over another. HP would therefore encourage
the Government to build upon existing systems of self-declaration
and continue to consult with industry to ensure that sustainable
procurement criteria are realistic, effective and workable.
Individual Producer Responsibility
26. IPR systems have and continue to exist
across the world in Japan, the Netherlands (until 2002), Maine,
and Washington State. These systems provide incentives for producers
to improve the design of their products.
27. HP is currently working with other producers,
academics and technical specialists to identify, explore and develop
practical solutions to IPR. In Japan the IPR system[1]
has led to the following benefits:
—
Unification of materials (plastics, magnetic alloys);
28. Without IPR, the WEEE directive is failing
one of its main objectives to establish an incentive for producers
to design products for easier recycling. The first step is to
ensure that Article 8.2 is properly transposed by Member States.
CONCLUSION
29. HP fully supports the Committee's decision
to explore the issue of waste reduction. We strongly believe that
minimising waste is a vital part of sustainable development which
is why this has been a priority for HP for over 15 years.
30. While this is a complex issue, we believe
that the most effective mechanisms for change are those that provide
powerful economic incentives for businesses to adapt their products
and processes. By integrating the principle of individual producer
responsibility into the regulatory framework and using the power
of public sector procurement, the Government is uniquely placed
to achieve this and drive the market for more sustainable products.
31. In a number of global markets there
are examples of both IPR and sustainable public procurement in
operation. We would strongly encourage government to examine these
examples of best practice and build on them rather than attempting
to "reinvent the wheel" which would risk increasing
the regulatory burden on businesses operating internationally.
32. In producing and taking forward its
recommendations we would urge the Committee to continue its dialogue
with the business community and consider ways in which the public
and private sector can work collaboratively to address issues
of waste reduction and environmental sustainability.
November 2007
1 Source: Naoko Tojo (2006) EPR program for
EEE in Japan: Brand Separation? Presentation to INSEAD
WEEE Directive Series, 30 November 2006. Back
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