January 30, 2025 • 29 mins
In this podcast episode, Stephanie McLarty speaks with Julie-Ann Adams about the evolving landscape of European legislation affecting sustainability, particularly in the realms of e-waste and battery recycling. They discuss the complexities of the EU Waste Shipment Regulation, the implications of the Basel Convention changes, and the upcoming battery legislation. Julie-Ann emphasizes the importance of understanding these regulations for companies operating in or exporting to Europe, highlighting the need for proactive measures to ensure compliance and sustainability.
Takeaways
- Europe is leading in environmental protections and legislation.
- The EU Waste Shipment Regulation has new administrative requirements.
- The Basel Convention now bans hazardous waste shipments to non-OECD countries.
- Battery legislation will require removable batteries by 2027.
- Companies need to understand the complexities of EU regulations.
- Networking and joining professional associations are crucial for compliance.
- Digital tracking of hazardous waste will enhance transparency.
- Proactivity is essential for companies to remain competitive.
- Understanding the supply chain is vital for compliance with new laws.
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Stephanie McLarty (00:08):
In today's interconnected world, new
legislation around the world canhave a significant impact on
your organization.
So what's happening in Europe?
Welcome to the circular future,your access to thought leaders
and innovations.
To help you be a businesssustainability champion, even if
it's not your core job.
(00:29):
I'm your host, StephanieMcLarty, Head of Sustainability
at Quantum Lifecycle Partners,your trusted partner in
electronics circularity.
Even if you don't do businessin a particular country, you may
be affected by its lawsindirectly through the
trickle-down effect of supplychains.
(00:49):
Today, we're going to cover newEuropean laws that you should
be aware of and may affect youeven if you don't operate in
Europe.
With me is Julie-Anne Adams,Secretary General of the
European Electronics RecyclersAssociation and the European
Battery Recyclers Association.
(01:09):
Julianne has been working inthe field of waste electronics
and batteries within Europe andon a global platform for 25
years.
Welcome to the podcast,Julianne.
Julie-Ann Adams (01:21):
Yes, thank you very much.
Nice to meet you.
Thank you very much for theinvitation to join you.
Stephanie McLarty (01:27):
Well, we are delighted to have you here and I
must say I don't know thatwe've ever had anyone on the
podcast who represents reallythree organizations.
So you represent the EuropeanElectronic Recyclers Association
, the European Battery RecyclersAssociation and Really Green
(01:47):
Credentials.
That is a lot.
You must be very busy.
Julie-Ann Adams (01:52):
Yes, it seemed like a good idea at the time,
but they're all interconnectedand so Really Green Credentials
is my own consultancy.
I've had that since 2008,having previously owned and
managed an e-waste recyclingplant in the UK and also before
(02:12):
that as an environmental andplanning lawyer.
So, 2008,.
I set up my own consultancy,developed into auditing and
developing standards for e-wasteand reuse of e-waste and
batteries had a batterycollection system.
So, yes, all sorts of things.
Era is the only dedicatedprofessional association for
(02:34):
e-waste reuse operators andrecyclers and the final end
processing, like the aluminiumand the copper and the plastic.
And ebra is the only dedicatedprofessional association for
battery collectors, sorters,logistics and recyclers.
And both of those associationscover the continent of Europe,
(02:55):
so it's not just limited to theEuropean Union.
So, for example, it includesthe United Kingdom, switzerland
and Norway, just the three mainones within the continent of
Europe.
And so, yes, it's a busy job,but it's one I've been doing a
long time, so I could probablydo most of it in my sleep.
Certainly, you know there's nota lot gets past me now as to
(03:17):
what's new.
Stephanie McLarty (03:19):
Well, I'm delighted to pick your brain
then on this podcast and thiswhole space.
Okay, so you mentioned ERA,which is the European
Electronics RecyclersAssociation, and EBRA, the
European Battery RecyclersAssociation.
We love acronyms, but sometimeswe need to spell them out.
I agree.
So we always start the podcastwith a little peek into your
(03:43):
world, but you've actuallyreally already given us a little
bit of what else would you say,what would be some things that
we wouldn't necessarily knowabout your work.
Julie-Ann Adams (03:53):
And so Europe is, I think, quite advanced
globally in terms of ensuringenvironmental and health and
safety protections protectionsand so my role in the last 25
years has been as a recycler, asa collector, developing
(04:14):
treatment standards and reusestandards and auditing as well.
I've done with my team at thetime.
I've stopped doing them now,but we did nearly 800 audits
right across Europe.
I've also worked for producersin Asia, looking at their
downstream and also out workingwith American companies and
Canadian companies importinginto Europe or exporting out of
Europe, which are ever-involving, as well as concerns that
(04:36):
operators have in Europe thattheir voice can all join
together to hopefully impact achange.
Stephanie McLarty (04:52):
Now, when we sit here in North America, we
often group Europe as a whole,but there often can be
differences.
You mentioned continentalEurope versus UK.
How should we wrap our headsaround this whole concept of
Europe and how the laws apply?
Julie-Ann Adams (05:13):
So you basically have sort of two areas
.
That really is the easiest wayto think of it.
So one is the European Union,which, following Brexit, now has
27 European members, and thatincludes the Republic of Ireland
as well, and France and Germanyand so on.
Then you have the UnitedKingdom, who are part of the EEA
(05:35):
European Economics Affiliation,I think that the A stands for
and then you also have countrieslike Switzerland, switzerland
who sort of are standalone.
So basically you've got the EUand everybody else.
Unfortunately, if you take theEU redirective as a bad example,
(05:56):
the redirective is aimed atEuropean Union members and
because it's a directive, itmeans that member states France,
germany could take thatlegislation in the directive and
put their own wording in.
So what we have is onedirective but 27 different
versions.
And if you take Germany further, they're a federal country and
(06:21):
so they can have different ruleswithin each federal area of
European Union and everybodyelse.
And then, of course, you havethat third sector, the third
ring, which is outside of all ofthat.
So Canada and the US and Japanand Asia and so on.
Very cool.
Stephanie McLarty (06:43):
Okay, I was just going to say it's not
necessarily an easy answer, butthank you for that.
It's been often said thatwhatever is happening in Europe
is probably three or so yearsaway to being implemented in
Canada and perhaps after thatthe United States and beyond.
You are leaders in Europe, sothat would be one reason for
(07:06):
companies to pay attention towhat's happening in Europe, to
what's happening in Europe.
But, in your words, what wouldyou say are the reasons why
non-European companies shouldpay attention to what's
happening in Europe?
Julie-Ann Adams (07:22):
And any company importing or exporting into
Europe if we call it as a wholereally does need to pay
attention so that not only thethe waste situation at the end
of life, but also if you're amanufacturer and you you want to
sell your products into Europevery important because there are
(07:42):
new laws for for that to dowith environmental protection as
well.
So electronic equipment has tonow comply with eco and green
legislation.
They have to have eco design,they have to consider the end of
life.
Very shortly they're going tohave to consider having
(08:02):
removable batteries, so aproduct will not be sold, be
able to be sold in europe andthe uk will follow if the
battery cannot be removed by theend user, the consumer, for
example, or by a professional.
So that's one very good reasonis that it's not just about
waste and it's not about the endof life, but it is about this,
(08:24):
you know, sort of cradle to thegrave, as they call it.
The other reason is thatconsignments can be stopped.
The other reason is thatconsignments can be stopped, so
not only imports of wholeequipment, but also exports of
materials that are outside ofEurope.
They might want to have copperbeing one, aluminium being
another, electronic componentsand so on, circuit boards, if
(08:49):
they're stopped at a portbecause the paperwork is
incorrect, that can cost a lotof money and a lot of time.
So demurrage charges, storagecharges, missing a ship, missing
the tides, you know all thesethings and obviously they're not
having the materials that youmight need, especially in
today's world of the sort of theconcerns about the, the numbers
(09:10):
of critical raw materials.
So you know China isring-fencing everything and
holding onto it, and that'sobviously where most of the
world's manufacturing takesplace.
But other manufacturers outsideof China really need to
consider their supply chains.
So it's very important tomonitor what happens in Europe,
and I totally agree that whathappens in Europe does filter
(09:33):
down.
I've been out to manyconferences in the US with INSRI
, which is now REMA, and acouple of years back I said, oh,
there's the e-waste Basel codesand they're going.
No, it's not going to impact us.
And of course now it is, and sothat's one example Examples of
environmental protectioncontrols on shipments and
(09:56):
exports right across the world.
So you know there is a lot ofthings that happen in Europe
that will filter down.
Australia are also following itand I know other countries and
regions have copied European lawand are implementing it.
Canada and Australia are at theforefront.
Stephanie McLarty (10:17):
Right, and I know we're not going to cover
today about the CSRD, forexample, the Corporate
Sustainability ReportingDirective but that's another
great example of how it startedin Europe, and Canada and
Australia are following suitwith their own versions, so I'll
have to stay tuned on that.
Julie-Ann Adams (10:36):
Yeah, and there's already been big fines,
big fines for companiesimporting into Europe that
haven't complied.
Stephanie McLarty (10:43):
Right, so fines.
There's another reason to stayon top of this whole area.
Yeah, so we're going to talktoday about three new
legislations the EU wasteshipment regulation, the Basel
Convention changes and thebattery legislation, article 8.
Before we get into all of thoseand you've explained how when
(11:05):
we think about Europe as a whole, it's actually quite complex.
So how do these threelegislation apply into this
concept of Europe?
I mean, who is truly impactedby them?
Geographically?
You know the type of companiesor even the size of companies.
Julie-Ann Adams (11:24):
I mean primarily the United Kingdom
following Brexit.
I have an Irish passport so itdoesn't impact me, but in the
United Kingdom we have NorthernIreland and there's a special
arrangement currently fromNorthern Ireland to the Republic
of Ireland and a lot ofmaterials and products, you know
, transfer from the north to thesouth daily, and so that's a
(11:47):
complex area and the rules arechanging and the administration
is changing From the UK intomainland European Union, where a
lot of the materials areprocessed or made.
Even there are again additionaladministration rules, much more
documentation and documents.
(12:08):
In terms of providing financialguarantees.
Switzerland is kind of the same, but they tend to be more
autonomous and just sort ofreally work on their own.
They have some e-productscoming in and some waste coming
out, but generally speaking theyrun on their own.
Within the European Union, as Imentioned, you can have
different versions and that'swhat ERA and RIBA really
(12:32):
advocate for.
We need a harmonious approachbecause our members don't just
live and work and trade in onecountry.
You know they want to putthings on a truck and drive them
from France to Poland and youknow if the legislation changes
between each country it has todrive through, it becomes very,
very difficult and you know, andthe operators, the recyclers,
(12:53):
have to try and, a know what todo, b ensure their staff
training is up to date and theirdrivers are up to date and
their paperwork is up to date,and somebody has to pay for all
of that.
And with the legislation,that's all going back on the
producers, the manufacturers.
So, yeah, it's very hard, veryhard.
Stephanie McLarty (13:15):
And for the size of companies that are
impacted by these legislations,it's basically any size.
If you're doing business, thenyou need to pay attention to
this.
Julie-Ann Adams (13:24):
Yeah.
Stephanie McLarty (13:24):
Okay, any size at all there's no
diminutiveness.
Okay, so let's start with theEU waste shipment regulation and
I'd love for you to give alittle overview of what this
legislation is and, you know,even like opportunities and
challenges around it.
Julie-Ann Adams (13:40):
Yes, we probably haven't got all day,
but I'll try and say we don't.
So we currently have sort oftwo running parallel.
We have what we call thecurrent or old waste shipment
regulation and then we have thenew waste shipment legislation
that came into force last year.
That um?
Um involves lots more um sortof administration requirements,
(14:04):
but actually it also easesthings, because there are a lot
of problems in the current onebecause member states can make
up their own mind and some mighttake six months, some might
take four years to get anotification through, which is
just crazy.
So there's more timeconstraints on member states for
them to work to a propertimetable, which is great for
everybody else.
(14:25):
There is also more in the newwaste shipments about the
harmonization and also a digitaltracking system that will come
into place in 2026.
So only hazardous waste, as anexample, will then have to be
tracked digitally and throughthe pre-informed consent process
, so that there's much moretransparency on where things are
(14:47):
going and the volumes and thetype of materials.
There is also one big change anda lot of materials from e-waste
and battery recycling isexported out of Europe currently
, and the big change in November2027 will be that any outside
recycling company will have toprovide an independent, verified
(15:11):
audit to a company wishing toimport to them, to a company
wishing to import to them.
So the verification and auditprocess is still being decided.
But it has to be done by thecountry of destination.
So it has to be, you know, youcan't just have you know, sort
of me saying, oh, I'm an auditor, I can sign off your report.
It has to be a proper auditingcompany and so that's going to
(15:34):
be quite complex.
As I said, the details aren'tknown, which isn't helping um,
and we have more details in thewaste shipment regulation than
we do in the other two um.
But you know, if you're anoperator you need to be planning
in advance and things can taketime and getting a notification
approval to move waste,especially hazardous waste, as I
(15:55):
say, can be anywhere from sixmonths to.
Let's say, we have one of ourmembers who's been waiting four
years to move plastic, fouryears from plastic to Portugal,
you know, and it's a verifiable,licensed site, it's going to,
but the Portuguese authoritiesare going.
Oh well, can you just tell usabout this one question, because
they're allowed to do it andtransit countries are just a
(16:17):
nightmare.
So you know, if your ship portum docks in malta, you could
wait another eight months beforethe maltese competent authority
say oh well, okay, it doesn'tmatter, it's not even being
unloaded.
Wow, you know that the wasteshipment regulations started in
the 1980s to try and preventhazardous waste from ending up
in ghana and and so on, just inall these dump sites.
(16:41):
But it hasn't moved with thetimes.
You know ships have changed andso you know the methods are
very different.
But I'm on a couple of the UNgroups trying to update and
upgrade the guidance.
But that's a very slow-turningship.
Stephanie McLarty (17:00):
We hear here in North America about the work
you're doing on digital productpassports.
You mentioned about thedigitization of tracking
everything.
Is there a connection there, orwill there be a connection, do
you think, with the digitalproduct passports?
Julie-Ann Adams (17:15):
Not to do with the waste shipment regulations.
That's more about theconsignment documents, um, and
the battery regulations.
Are implementing the batterypassports sooner than the we
regulations, the e-wasteregulations.
So, um, the two are quitedifferent, although, as I say,
at the moment we don't know.
We don't even know where it'sgoing to be um, upended, let
(17:35):
alone how, what it looks like.
But they've got until Augustnext year for the way shipments
and the battery regulations toget this sorted.
Stephanie McLarty (17:48):
So August this year beg your pardon, we're
2025.
We're in 2025.
Julie-Ann Adams (17:51):
Yeah, I know exactly.
So, yes, the time is ticking,but you know the people in the
European Commission.
They're not industrial people,they're not um, you know most of
them.
Some of them are, but most ofthem are not.
So they don't understand thecomplexity of the the supply
chain.
They don't understand howthings are collected and the
digital product passport if wemove on to that and the e-waste
(18:13):
regulations are going to be verydifficult because they're that
there's not going to be onesolution, so a producer can find
their own solution, which meanseverybody else has to try and
work out where that informationis.
But it's basically aimed atupdating and giving consumers
better choice.
So if you wanted a new washingmachine, you could scan a QR
(18:35):
code at your retailer and itwould tell you.
You know what its environmentalmerits are, what its energy use
is, where it was made, if it'sgot any hazardous substances in,
if it has been prepared forreuse as well.
That will also be in theproduct passport, which will be
useful because people can makean informed choice rather than
you know believing an advert orsomething.
(18:56):
Informed choice rather than youknow believing an advert or
something.
Stephanie McLarty (19:00):
So there are benefits, but when it gets to
recycling, it's just going to,you know, be chaos, but we'll
see.
Julie-Ann Adams (19:06):
Okay, that will be a future podcast episode.
Yeah, yes, yes.
Stephanie McLarty (19:09):
Let's talk about the third one, which is
the battery legislation, Article8.
What is that?
Julie-Ann Adams (19:19):
Yes, so Article 8 is where everything is
supposed to come together, it'ssupposed to be, it's supposed to
be implemented I think it's the25th of august, the 18th of
august this year, um, wherethere is supposed to be the
rules and the, the, the sort ofthe guidance, if you like, the
details of what happens forbattery collections, battery
targets, the CO2 calculationsand recovery and recycled
(19:43):
material content.
The commission are very farbehind, in my opinion.
You know we're talking aboutAugust, so that's like eight
months, seven months now, andwe're still discussing.
You know, the finer points.
Some things are getting to aconclusion, one being the, as I
mentioned earlier, theremovability of batteries.
(20:05):
So by 2027, no product can beplaced on the market where a
battery cannot be removed.
They produced the Joint ResearchCouncil, for the Commission
produced quite a good document,27 pages but not once did it
mention what you do with thebattery when you take it out,
which was a bit of a flaw in myopinion, because it's supposed
(20:26):
to be the safety paragraphsaying when you've removed the
batteries consumer orprofessional person you need to
dispose of it responsibly in theright container, tape up the
terminals.
You know that sort of thing,just, you know, not too overly
complex but um, but yes, it's,it's.
(20:47):
It's a challenge, and the themethodology of um, as another
example of co2 um calculationsimpacts producers, because
that's where it starts.
So producers of batteries haveto be talking to their supply
chain to say, okay, what's yourco2 footprint?
How you know, we need todetermine our share because
(21:08):
we're the ones that areresponsible, um, and so the
methodology of that is, again,not completely finished.
We're're really urging theCommission to make sure that
European recyclers are notpenalised by this, by making
sure that all the rules andregulations and licensing and
(21:29):
costs that European operatorshave must be replicated in other
countries.
So if you're making batteriesin China, as an example, you
need to be meeting the same kindof obligations and reporting as
anybody in Europe, otherwiseyou don't have a level playing
field.
Stephanie McLarty (21:46):
So very important, absolutely and
certainly internationalstandards aim to level that
playing field right.
Yes, yes, yes, especiallythrough harmonization.
Julie-Ann Adams (21:57):
Yes, Having been involved in drafting
standards, you know they cantake years, so the one took.
Stephanie McLarty (22:07):
I think it was seven years before we
finalized it.
Julie-Ann Adams (22:09):
So yeah, I'll probably be retired by the time
it comes in.
Stephanie McLarty (22:13):
So we'll definitely have to stay tuned on
this battery legislation as itcomes out and what the final
details are in summer 2025.
Okay, Julianne, let's move intoour how-to section of the
podcast, where I ask you how-toquestions, and I have to admit
you've given us so muchinformation and so much to think
about.
How do we actually wrap ourheads around?
(22:36):
It is the next step.
So, first question how todecide what actions to take in
all of this?
We know there's newlegislations like what do you
actually do as a company?
Julie-Ann Adams (22:50):
If you're a recycling company or you are in
receipt of waste materials, youreally need to be making sure
you're following all thelegislation and obviously
joining a dedicated professionalassociation is step number one,
but also, you know, havingcompetent staff on board
(23:10):
liaising with other stakeholders.
You know we have manynetworking events between the
e-waste members and the batterymembers because you know they
need to share that information.
That logistics is one big thingmaking sure that everybody in
your supply chain understandsand is keeping up to date.
So if you're a producer inamerica and you're looking to
(23:32):
sell products into europe, youknow your supply chain will be.
Who is the registered importerin each european union member
state?
Have they complied withregistering and making sure that
they're contributing to theend-of-life obligations?
So, yeah, it's just really aquestion of you can watch our
(23:53):
websites.
We are on LinkedIn and Twitteras well because we provide that
kind of information.
Stephanie McLarty (24:05):
So that would be the two things is networking
stakeholders and joining ERAand EBRA.
Okay, awesome, and we will linkthose websites in the show
notes as well.
You can find them Okay.
Second question it sounds likein certain cases that there may
be more paperwork, there may bemore administrative burden, if
you will.
How to deal with that as acompany, and especially because
a lot of companies are eithersmall or they don't have a large
(24:27):
staff dedicated to this?
Julie-Ann Adams (24:30):
Absolutely, and I know we're not talking about
environmental social governance.
But you know, if you're amassive, big global company,
you'll have a whole departmentand probably 15 people.
But if you're a family business, many of our members are family
businesses.
Our president started hisbusiness 51 years ago and so you
know they need to know how todo this.
(24:51):
And again, you know it's reallytrying to find the European
Commission paperwork and they dohave several quite good
websites, but you know it'sEuropean speak, but it's about
making sure you don't breachyour local, national legislation
first.
So talk to your competenceauthority, talk to your
(25:14):
environmental agency, talk toyour health and safety
legislative team, because allthose governmental organisations
should be able to provide someinformation and get yourself on
email lists and and that sort ofthing to keep up to date a big
burden.
And when I started in recycling25 years ago, there was me in
(25:37):
our environmental department,you know, and, and we were a
small company, you know.
Now that probably needs an, youknow, team of five or six or
more for just a very smallcompany, so just dedicated to
the administration.
Stephanie McLarty (25:50):
Yeah, and that's a reality for a lot of
companies.
Okay, last question and you'vealready somewhat touched on it
is really how to stay up to datewith all of these changes.
Is it follow EBRA and ERA andsign up for as many mailing
lists as you can?
Julie-Ann Adams (26:07):
Yeah, I think that's probably the best and
easiest and quickest advice.
You know, if you have arecycling facility in Europe,
you can apply to be a member ofeither.
For Ibra they also have anassociate membership status, so
we have a member in Canada, forexample, and one in Australia.
So they haven't got a facilityin Europe, but they can be an
(26:30):
associate member and, again,gain that insight.
It just means that they can'tvote at the AGM.
It's not a big deal and it's acheaper fee as well.
But, yes, I think really it's aquestion of just monitoring the
changes.
I know in the United Statesthere's this discussion over the
(26:51):
difference between scrap andwaste, of which I totally
understand and would support ifwe could have a.
This isn't waste, because thiscopper is going to be reused.
But you know again, turningthat ship is going to take a
long, long time.
But it's that understandingthat you might call it scrap in
america, but actually the restof the world is now moving
(27:13):
towards using it as a waste andit needs to be tracked and it's
to prevent.
You know, and improveenvironmental and health and
safety, um, of everybody in thechain.
Um, you know, when I've auditedsites in china, um and and
northern africa where the, thewere pitiful small children, you
know, handpicking copper cables, for example, and burning the
(27:36):
plastics, you know, and they'vegot saws and cuts and you know,
and so there are lots of impactsand so this isn't done.
You know, on a whim.
You know, let's increaseeveryone's administration.
It's done for a reason toprevent.
You know, let's increaseeveryone's administration.
It's done for a reason toprevent.
You know, the improper use ofhazardous substances.
Stephanie McLarty (27:53):
Absolutely, and thank you for taking us back
to the real purpose behind allof this is to be great stewards
for our planet and for folks inother countries.
Julian, I feel like my eyeshave been opened through this
and the thing that's occurringfor me is really the only
constant is change, and we needto stay on top of change.
(28:14):
What would be one final pieceof advice you would leave our
listeners with in terms of thischange and staying on top of it?
Julie-Ann Adams (28:24):
I think, making sure you're proactive rather
than reactive.
You know, it's all very well toput your head in the sand and
wait till somebody knocks on thedoor and go oh, I've stopped
your shipment because of X, y orZ.
You know, if you're proactiveand you understand this, then
you're going to remaincompetitive because you can be
sure that your competitors, youknow, are also going down that
(28:46):
route.
So that's the biggest piece ofvery simple advice be proactive
and not reactive.
Stephanie McLarty (28:55):
Yeah don't wait.
Thank you so much, julianne.
This was incredibly insightfuland I really appreciate you
taking the time to share yourinsights with us.
Julie-Ann Adams (29:03):
Yeah, no, that's good.
I'm always happy to work on aglobal basis Amazing.
Stephanie McLarty (29:09):
Let's get them all happy to work on a
global basis.
Amazing, and remember.
If you're looking for a partnerto help you repair, reuse or
recycle your electronics inCanada or Costa Rica, we'd love
to chat.
Head on over toquantumlifecyclecom and contact
us.
This is a Quantum Lifecyclepodcast and the producer is
Sanjay Trivedi.
Thank you for being a CircularFuture Champion in your company
(29:29):
and beyond.
Logging off.
In today's interconnected world, new
legislation around the world canhave a significant impact on
your organization.
So what's happening in Europe?
Welcome to the circular future,your access to thought leaders
and innovations.
To help you be a businesssustainability champion, even if
it's not your core job.
(00:29):
I'm your host, StephanieMcLarty, Head of Sustainability
at Quantum Lifecycle Partners,your trusted partner in
electronics circularity.
Even if you don't do businessin a particular country, you may
be affected by its lawsindirectly through the
trickle-down effect of supplychains.
(00:49):
Today, we're going to cover newEuropean laws that you should
be aware of and may affect youeven if you don't operate in
Europe.
With me is Julie-Anne Adams,Secretary General of the
European Electronics RecyclersAssociation and the European
Battery Recyclers Association.
(01:09):
Julianne has been working inthe field of waste electronics
and batteries within Europe andon a global platform for 25
years.
Welcome to the podcast,Julianne.
Julie-Ann Adams (01:21):
Yes, thank you very much.
Nice to meet you.
Thank you very much for theinvitation to join you.
Stephanie McLarty (01:27):
Well, we are delighted to have you here and I
must say I don't know thatwe've ever had anyone on the
podcast who represents reallythree organizations.
So you represent the EuropeanElectronic Recyclers Association
, the European Battery RecyclersAssociation and Really Green
(01:47):
Credentials.
That is a lot.
You must be very busy.
Julie-Ann Adams (01:52):
Yes, it seemed like a good idea at the time,
but they're all interconnectedand so Really Green Credentials
is my own consultancy.
I've had that since 2008,having previously owned and
managed an e-waste recyclingplant in the UK and also before
(02:12):
that as an environmental andplanning lawyer.
So, 2008,.
I set up my own consultancy,developed into auditing and
developing standards for e-wasteand reuse of e-waste and
batteries had a batterycollection system.
So, yes, all sorts of things.
Era is the only dedicatedprofessional association for
(02:34):
e-waste reuse operators andrecyclers and the final end
processing, like the aluminiumand the copper and the plastic.
And ebra is the only dedicatedprofessional association for
battery collectors, sorters,logistics and recyclers.
And both of those associationscover the continent of Europe,
(02:55):
so it's not just limited to theEuropean Union.
So, for example, it includesthe United Kingdom, switzerland
and Norway, just the three mainones within the continent of
Europe.
And so, yes, it's a busy job,but it's one I've been doing a
long time, so I could probablydo most of it in my sleep.
Certainly, you know there's nota lot gets past me now as to
(03:17):
what's new.
Stephanie McLarty (03:19):
Well, I'm delighted to pick your brain
then on this podcast and thiswhole space.
Okay, so you mentioned ERA,which is the European
Electronics RecyclersAssociation, and EBRA, the
European Battery RecyclersAssociation.
We love acronyms, but sometimeswe need to spell them out.
I agree.
So we always start the podcastwith a little peek into your
(03:43):
world, but you've actuallyreally already given us a little
bit of what else would you say,what would be some things that
we wouldn't necessarily knowabout your work.
Julie-Ann Adams (03:53):
And so Europe is, I think, quite advanced
globally in terms of ensuringenvironmental and health and
safety protections protectionsand so my role in the last 25
years has been as a recycler, asa collector, developing
(04:14):
treatment standards and reusestandards and auditing as well.
I've done with my team at thetime.
I've stopped doing them now,but we did nearly 800 audits
right across Europe.
I've also worked for producersin Asia, looking at their
downstream and also out workingwith American companies and
Canadian companies importinginto Europe or exporting out of
Europe, which are ever-involving, as well as concerns that
(04:36):
operators have in Europe thattheir voice can all join
together to hopefully impact achange.
Stephanie McLarty (04:52):
Now, when we sit here in North America, we
often group Europe as a whole,but there often can be
differences.
You mentioned continentalEurope versus UK.
How should we wrap our headsaround this whole concept of
Europe and how the laws apply?
Julie-Ann Adams (05:13):
So you basically have sort of two areas
.
That really is the easiest wayto think of it.
So one is the European Union,which, following Brexit, now has
27 European members, and thatincludes the Republic of Ireland
as well, and France and Germanyand so on.
Then you have the UnitedKingdom, who are part of the EEA
(05:35):
European Economics Affiliation,I think that the A stands for
and then you also have countrieslike Switzerland, switzerland
who sort of are standalone.
So basically you've got the EUand everybody else.
Unfortunately, if you take theEU redirective as a bad example,
(05:56):
the redirective is aimed atEuropean Union members and
because it's a directive, itmeans that member states France,
germany could take thatlegislation in the directive and
put their own wording in.
So what we have is onedirective but 27 different
versions.
And if you take Germany further, they're a federal country and
(06:21):
so they can have different ruleswithin each federal area of
European Union and everybodyelse.
And then, of course, you havethat third sector, the third
ring, which is outside of all ofthat.
So Canada and the US and Japanand Asia and so on.
Very cool.
Stephanie McLarty (06:43):
Okay, I was just going to say it's not
necessarily an easy answer, butthank you for that.
It's been often said thatwhatever is happening in Europe
is probably three or so yearsaway to being implemented in
Canada and perhaps after thatthe United States and beyond.
You are leaders in Europe, sothat would be one reason for
(07:06):
companies to pay attention towhat's happening in Europe, to
what's happening in Europe.
But, in your words, what wouldyou say are the reasons why
non-European companies shouldpay attention to what's
happening in Europe?
Julie-Ann Adams (07:22):
And any company importing or exporting into
Europe if we call it as a wholereally does need to pay
attention so that not only thethe waste situation at the end
of life, but also if you're amanufacturer and you you want to
sell your products into Europevery important because there are
(07:42):
new laws for for that to dowith environmental protection as
well.
So electronic equipment has tonow comply with eco and green
legislation.
They have to have eco design,they have to consider the end of
life.
Very shortly they're going tohave to consider having
(08:02):
removable batteries, so aproduct will not be sold, be
able to be sold in europe andthe uk will follow if the
battery cannot be removed by theend user, the consumer, for
example, or by a professional.
So that's one very good reasonis that it's not just about
waste and it's not about the endof life, but it is about this,
(08:24):
you know, sort of cradle to thegrave, as they call it.
The other reason is thatconsignments can be stopped.
The other reason is thatconsignments can be stopped, so
not only imports of wholeequipment, but also exports of
materials that are outside ofEurope.
They might want to have copperbeing one, aluminium being
another, electronic componentsand so on, circuit boards, if
(08:49):
they're stopped at a portbecause the paperwork is
incorrect, that can cost a lotof money and a lot of time.
So demurrage charges, storagecharges, missing a ship, missing
the tides, you know all thesethings and obviously they're not
having the materials that youmight need, especially in
today's world of the sort of theconcerns about the, the numbers
(09:10):
of critical raw materials.
So you know China isring-fencing everything and
holding onto it, and that'sobviously where most of the
world's manufacturing takesplace.
But other manufacturers outsideof China really need to
consider their supply chains.
So it's very important tomonitor what happens in Europe,
and I totally agree that whathappens in Europe does filter
(09:33):
down.
I've been out to manyconferences in the US with INSRI
, which is now REMA, and acouple of years back I said, oh,
there's the e-waste Basel codesand they're going.
No, it's not going to impact us.
And of course now it is, and sothat's one example Examples of
environmental protectioncontrols on shipments and
(09:56):
exports right across the world.
So you know there is a lot ofthings that happen in Europe
that will filter down.
Australia are also following itand I know other countries and
regions have copied European lawand are implementing it.
Canada and Australia are at theforefront.
Stephanie McLarty (10:17):
Right, and I know we're not going to cover
today about the CSRD, forexample, the Corporate
Sustainability ReportingDirective but that's another
great example of how it startedin Europe, and Canada and
Australia are following suitwith their own versions, so I'll
have to stay tuned on that.
Julie-Ann Adams (10:36):
Yeah, and there's already been big fines,
big fines for companiesimporting into Europe that
haven't complied.
Stephanie McLarty (10:43):
Right, so fines.
There's another reason to stayon top of this whole area.
Yeah, so we're going to talktoday about three new
legislations the EU wasteshipment regulation, the Basel
Convention changes and thebattery legislation, article 8.
Before we get into all of thoseand you've explained how when
(11:05):
we think about Europe as a whole, it's actually quite complex.
So how do these threelegislation apply into this
concept of Europe?
I mean, who is truly impactedby them?
Geographically?
You know the type of companiesor even the size of companies.
Julie-Ann Adams (11:24):
I mean primarily the United Kingdom
following Brexit.
I have an Irish passport so itdoesn't impact me, but in the
United Kingdom we have NorthernIreland and there's a special
arrangement currently fromNorthern Ireland to the Republic
of Ireland and a lot ofmaterials and products, you know
, transfer from the north to thesouth daily, and so that's a
(11:47):
complex area and the rules arechanging and the administration
is changing From the UK intomainland European Union, where a
lot of the materials areprocessed or made.
Even there are again additionaladministration rules, much more
documentation and documents.
(12:08):
In terms of providing financialguarantees.
Switzerland is kind of the same, but they tend to be more
autonomous and just sort ofreally work on their own.
They have some e-productscoming in and some waste coming
out, but generally speaking theyrun on their own.
Within the European Union, as Imentioned, you can have
different versions and that'swhat ERA and RIBA really
(12:32):
advocate for.
We need a harmonious approachbecause our members don't just
live and work and trade in onecountry.
You know they want to putthings on a truck and drive them
from France to Poland and youknow if the legislation changes
between each country it has todrive through, it becomes very,
very difficult and you know, andthe operators, the recyclers,
(12:53):
have to try and, a know what todo, b ensure their staff
training is up to date and theirdrivers are up to date and
their paperwork is up to date,and somebody has to pay for all
of that.
And with the legislation,that's all going back on the
producers, the manufacturers.
So, yeah, it's very hard, veryhard.
Stephanie McLarty (13:15):
And for the size of companies that are
impacted by these legislations,it's basically any size.
If you're doing business, thenyou need to pay attention to
this.
Julie-Ann Adams (13:24):
Yeah.
Stephanie McLarty (13:24):
Okay, any size at all there's no
diminutiveness.
Okay, so let's start with theEU waste shipment regulation and
I'd love for you to give alittle overview of what this
legislation is and, you know,even like opportunities and
challenges around it.
Julie-Ann Adams (13:40):
Yes, we probably haven't got all day,
but I'll try and say we don't.
So we currently have sort oftwo running parallel.
We have what we call thecurrent or old waste shipment
regulation and then we have thenew waste shipment legislation
that came into force last year.
That um?
Um involves lots more um sortof administration requirements,
(14:04):
but actually it also easesthings, because there are a lot
of problems in the current onebecause member states can make
up their own mind and some mighttake six months, some might
take four years to get anotification through, which is
just crazy.
So there's more timeconstraints on member states for
them to work to a propertimetable, which is great for
everybody else.
(14:25):
There is also more in the newwaste shipments about the
harmonization and also a digitaltracking system that will come
into place in 2026.
So only hazardous waste, as anexample, will then have to be
tracked digitally and throughthe pre-informed consent process
, so that there's much moretransparency on where things are
(14:47):
going and the volumes and thetype of materials.
There is also one big change anda lot of materials from e-waste
and battery recycling isexported out of Europe currently
, and the big change in November2027 will be that any outside
recycling company will have toprovide an independent, verified
(15:11):
audit to a company wishing toimport to them, to a company
wishing to import to them.
So the verification and auditprocess is still being decided.
But it has to be done by thecountry of destination.
So it has to be, you know, youcan't just have you know, sort
of me saying, oh, I'm an auditor, I can sign off your report.
It has to be a proper auditingcompany and so that's going to
(15:34):
be quite complex.
As I said, the details aren'tknown, which isn't helping um,
and we have more details in thewaste shipment regulation than
we do in the other two um.
But you know, if you're anoperator you need to be planning
in advance and things can taketime and getting a notification
approval to move waste,especially hazardous waste, as I
(15:55):
say, can be anywhere from sixmonths to.
Let's say, we have one of ourmembers who's been waiting four
years to move plastic, fouryears from plastic to Portugal,
you know, and it's a verifiable,licensed site, it's going to,
but the Portuguese authoritiesare going.
Oh well, can you just tell usabout this one question, because
they're allowed to do it andtransit countries are just a
(16:17):
nightmare.
So you know, if your ship portum docks in malta, you could
wait another eight months beforethe maltese competent authority
say oh well, okay, it doesn'tmatter, it's not even being
unloaded.
Wow, you know that the wasteshipment regulations started in
the 1980s to try and preventhazardous waste from ending up
in ghana and and so on, just inall these dump sites.
(16:41):
But it hasn't moved with thetimes.
You know ships have changed andso you know the methods are
very different.
But I'm on a couple of the UNgroups trying to update and
upgrade the guidance.
But that's a very slow-turningship.
Stephanie McLarty (17:00):
We hear here in North America about the work
you're doing on digital productpassports.
You mentioned about thedigitization of tracking
everything.
Is there a connection there, orwill there be a connection, do
you think, with the digitalproduct passports?
Julie-Ann Adams (17:15):
Not to do with the waste shipment regulations.
That's more about theconsignment documents, um, and
the battery regulations.
Are implementing the batterypassports sooner than the we
regulations, the e-wasteregulations.
So, um, the two are quitedifferent, although, as I say,
at the moment we don't know.
We don't even know where it'sgoing to be um, upended, let
(17:35):
alone how, what it looks like.
But they've got until Augustnext year for the way shipments
and the battery regulations toget this sorted.
Stephanie McLarty (17:48):
So August this year beg your pardon, we're
2025.
We're in 2025.
Julie-Ann Adams (17:51):
Yeah, I know exactly.
So, yes, the time is ticking,but you know the people in the
European Commission.
They're not industrial people,they're not um, you know most of
them.
Some of them are, but most ofthem are not.
So they don't understand thecomplexity of the the supply
chain.
They don't understand howthings are collected and the
digital product passport if wemove on to that and the e-waste
(18:13):
regulations are going to be verydifficult because they're that
there's not going to be onesolution, so a producer can find
their own solution, which meanseverybody else has to try and
work out where that informationis.
But it's basically aimed atupdating and giving consumers
better choice.
So if you wanted a new washingmachine, you could scan a QR
(18:35):
code at your retailer and itwould tell you.
You know what its environmentalmerits are, what its energy use
is, where it was made, if it'sgot any hazardous substances in,
if it has been prepared forreuse as well.
That will also be in theproduct passport, which will be
useful because people can makean informed choice rather than
you know believing an advert orsomething.
(18:56):
Informed choice rather than youknow believing an advert or
something.
Stephanie McLarty (19:00):
So there are benefits, but when it gets to
recycling, it's just going to,you know, be chaos, but we'll
see.
Julie-Ann Adams (19:06):
Okay, that will be a future podcast episode.
Yeah, yes, yes.
Stephanie McLarty (19:09):
Let's talk about the third one, which is
the battery legislation, Article8.
What is that?
Julie-Ann Adams (19:19):
Yes, so Article 8 is where everything is
supposed to come together, it'ssupposed to be, it's supposed to
be implemented I think it's the25th of august, the 18th of
august this year, um, wherethere is supposed to be the
rules and the, the, the sort ofthe guidance, if you like, the
details of what happens forbattery collections, battery
targets, the CO2 calculationsand recovery and recycled
(19:43):
material content.
The commission are very farbehind, in my opinion.
You know we're talking aboutAugust, so that's like eight
months, seven months now, andwe're still discussing.
You know, the finer points.
Some things are getting to aconclusion, one being the, as I
mentioned earlier, theremovability of batteries.
(20:05):
So by 2027, no product can beplaced on the market where a
battery cannot be removed.
They produced the Joint ResearchCouncil, for the Commission
produced quite a good document,27 pages but not once did it
mention what you do with thebattery when you take it out,
which was a bit of a flaw in myopinion, because it's supposed
(20:26):
to be the safety paragraphsaying when you've removed the
batteries consumer orprofessional person you need to
dispose of it responsibly in theright container, tape up the
terminals.
You know that sort of thing,just, you know, not too overly
complex but um, but yes, it's,it's.
(20:47):
It's a challenge, and the themethodology of um, as another
example of co2 um calculationsimpacts producers, because
that's where it starts.
So producers of batteries haveto be talking to their supply
chain to say, okay, what's yourco2 footprint?
How you know, we need todetermine our share because
(21:08):
we're the ones that areresponsible, um, and so the
methodology of that is, again,not completely finished.
We're're really urging theCommission to make sure that
European recyclers are notpenalised by this, by making
sure that all the rules andregulations and licensing and
(21:29):
costs that European operatorshave must be replicated in other
countries.
So if you're making batteriesin China, as an example, you
need to be meeting the same kindof obligations and reporting as
anybody in Europe, otherwiseyou don't have a level playing
field.
Stephanie McLarty (21:46):
So very important, absolutely and
certainly internationalstandards aim to level that
playing field right.
Yes, yes, yes, especiallythrough harmonization.
Julie-Ann Adams (21:57):
Yes, Having been involved in drafting
standards, you know they cantake years, so the one took.
Stephanie McLarty (22:07):
I think it was seven years before we
finalized it.
Julie-Ann Adams (22:09):
So yeah, I'll probably be retired by the time
it comes in.
Stephanie McLarty (22:13):
So we'll definitely have to stay tuned on
this battery legislation as itcomes out and what the final
details are in summer 2025.
Okay, Julianne, let's move intoour how-to section of the
podcast, where I ask you how-toquestions, and I have to admit
you've given us so muchinformation and so much to think
about.
How do we actually wrap ourheads around?
(22:36):
It is the next step.
So, first question how todecide what actions to take in
all of this?
We know there's newlegislations like what do you
actually do as a company?
Julie-Ann Adams (22:50):
If you're a recycling company or you are in
receipt of waste materials, youreally need to be making sure
you're following all thelegislation and obviously
joining a dedicated professionalassociation is step number one,
but also, you know, havingcompetent staff on board
(23:10):
liaising with other stakeholders.
You know we have manynetworking events between the
e-waste members and the batterymembers because you know they
need to share that information.
That logistics is one big thingmaking sure that everybody in
your supply chain understandsand is keeping up to date.
So if you're a producer inamerica and you're looking to
(23:32):
sell products into europe, youknow your supply chain will be.
Who is the registered importerin each european union member
state?
Have they complied withregistering and making sure that
they're contributing to theend-of-life obligations?
So, yeah, it's just really aquestion of you can watch our
(23:53):
websites.
We are on LinkedIn and Twitteras well because we provide that
kind of information.
Stephanie McLarty (24:05):
So that would be the two things is networking
stakeholders and joining ERAand EBRA.
Okay, awesome, and we will linkthose websites in the show
notes as well.
You can find them Okay.
Second question it sounds likein certain cases that there may
be more paperwork, there may bemore administrative burden, if
you will.
How to deal with that as acompany, and especially because
a lot of companies are eithersmall or they don't have a large
(24:27):
staff dedicated to this?
Julie-Ann Adams (24:30):
Absolutely, and I know we're not talking about
environmental social governance.
But you know, if you're amassive, big global company,
you'll have a whole departmentand probably 15 people.
But if you're a family business, many of our members are family
businesses.
Our president started hisbusiness 51 years ago and so you
know they need to know how todo this.
(24:51):
And again, you know it's reallytrying to find the European
Commission paperwork and they dohave several quite good
websites, but you know it'sEuropean speak, but it's about
making sure you don't breachyour local, national legislation
first.
So talk to your competenceauthority, talk to your
(25:14):
environmental agency, talk toyour health and safety
legislative team, because allthose governmental organisations
should be able to provide someinformation and get yourself on
email lists and and that sort ofthing to keep up to date a big
burden.
And when I started in recycling25 years ago, there was me in
(25:37):
our environmental department,you know, and, and we were a
small company, you know.
Now that probably needs an, youknow, team of five or six or
more for just a very smallcompany, so just dedicated to
the administration.
Stephanie McLarty (25:50):
Yeah, and that's a reality for a lot of
companies.
Okay, last question and you'vealready somewhat touched on it
is really how to stay up to datewith all of these changes.
Is it follow EBRA and ERA andsign up for as many mailing
lists as you can?
Julie-Ann Adams (26:07):
Yeah, I think that's probably the best and
easiest and quickest advice.
You know, if you have arecycling facility in Europe,
you can apply to be a member ofeither.
For Ibra they also have anassociate membership status, so
we have a member in Canada, forexample, and one in Australia.
So they haven't got a facilityin Europe, but they can be an
(26:30):
associate member and, again,gain that insight.
It just means that they can'tvote at the AGM.
It's not a big deal and it's acheaper fee as well.
But, yes, I think really it's aquestion of just monitoring the
changes.
I know in the United Statesthere's this discussion over the
(26:51):
difference between scrap andwaste, of which I totally
understand and would support ifwe could have a.
This isn't waste, because thiscopper is going to be reused.
But you know again, turningthat ship is going to take a
long, long time.
But it's that understandingthat you might call it scrap in
america, but actually the restof the world is now moving
(27:13):
towards using it as a waste andit needs to be tracked and it's
to prevent.
You know, and improveenvironmental and health and
safety, um, of everybody in thechain.
Um, you know, when I've auditedsites in china, um and and
northern africa where the, thewere pitiful small children, you
know, handpicking copper cables, for example, and burning the
(27:36):
plastics, you know, and they'vegot saws and cuts and you know,
and so there are lots of impactsand so this isn't done.
You know, on a whim.
You know, let's increaseeveryone's administration.
It's done for a reason toprevent.
You know, let's increaseeveryone's administration.
It's done for a reason toprevent.
You know, the improper use ofhazardous substances.
Stephanie McLarty (27:53):
Absolutely, and thank you for taking us back
to the real purpose behind allof this is to be great stewards
for our planet and for folks inother countries.
Julian, I feel like my eyeshave been opened through this
and the thing that's occurringfor me is really the only
constant is change, and we needto stay on top of change.
(28:14):
What would be one final pieceof advice you would leave our
listeners with in terms of thischange and staying on top of it?
Julie-Ann Adams (28:24):
I think, making sure you're proactive rather
than reactive.
You know, it's all very well toput your head in the sand and
wait till somebody knocks on thedoor and go oh, I've stopped
your shipment because of X, y orZ.
You know, if you're proactiveand you understand this, then
you're going to remaincompetitive because you can be
sure that your competitors, youknow, are also going down that
(28:46):
route.
So that's the biggest piece ofvery simple advice be proactive
and not reactive.
Stephanie McLarty (28:55):
Yeah don't wait.
Thank you so much, julianne.
This was incredibly insightfuland I really appreciate you
taking the time to share yourinsights with us.
Julie-Ann Adams (29:03):
Yeah, no, that's good.
I'm always happy to work on aglobal basis Amazing.
Stephanie McLarty (29:09):
Let's get them all happy to work on a
global basis.
Amazing, and remember.
If you're looking for a partnerto help you repair, reuse or
recycle your electronics inCanada or Costa Rica, we'd love
to chat.
Head on over toquantumlifecyclecom and contact
us.
This is a Quantum Lifecyclepodcast and the producer is
Sanjay Trivedi.
Thank you for being a CircularFuture Champion in your company
(29:29):
and beyond.
Logging off.
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