Australia’s Hazardous Waste Act regulates the export and import of hazardous waste into and out of Australia by way of the Basel Convention, Organisation of Economic Co-operation and Development Decision and the Waigani Convention. As a party to these conventions and agreements, Australia has an obligation to ensure that the stewardship legislation that applies to our waste and exporting activities does not impact on international destinations. As such, Australia’s responsibilities and obligations to the export of end products as a direct result of product stewardship activities lies with the manufacturer/producer and should not be contracted out to buyers, sellers, brokers or agents without appropriate due diligence.
Australia’s product stewardship arrangements are not alone or protected from ensuring that exported materials through the supply chain go to an environmentally sound use. This will become more important as new product stewardship programs are developed which could result in waste, that is not classified as hazardous in accordance with the Act its regulations, undergoing further treatment (dismantling for product recovery) or used in facilities (for example for energy recovery, energy generation or pyrolysis) that don’t have the same stringent controls in place to protect the environment or safeguards in place to protect the health and safety of workers. Other by-products might even be illegally dumped or incinerated.
With a number of Australian industries signalling a strong intension to move towards a circular economical way to value product and service inputs and outputs, we need to become smarter as to how we assess our downstream supply chains and in particular health and environmental impacts.
Equilibrium has started a review of international programs with the aim of providing guidance to Australian companies to ensure that they aren’t just providing a burden to other countries and enduring reputational risk but rather ensuring exported materials are destined for an environmentally sound use.
This guidance is expected to be completed in early 2017.