Advice to NEA on its Proposed E-Waste Management System

In July 2018, the National Environment Agency (“NEA”) sought CCCS’s advice on its proposal to implement a regulated electrical and electronic waste (“e-waste”) management system in Singapore by 2021.

Under this system, it will be mandatory for producers of electrical and electronic equipment (“EEE producers”) to engage a Producer Responsibility Organisation (“PRO”) to help them ensure the collection and proper treatment of e-waste that results from their supply of the equipment. The PRO will have to meet NEA-prescribed collection targets, and the PRO will need to ensure that all e-waste collected is properly processed by NEA-licensed e-waste recycling companies (“EWRs”).

In its request for advice, NEA sought CCCS’s views on how the legislative and licensing regimes that will govern the PRO could be structured to ensure that there is fair competition in the e-waste recycling market. CCCS pointed out the competition concerns that could result from vertical integration between the PRO and EWRs and the formation of PRO by EEE producers, and recommended various licensing conditions and enforcement mechanisms that would ensure sufficient choices for all users of the services provided by the PRO and EWRs. CCCS also provided some recommendations on how competition could be promoted in the e-waste recycling market in the longer term, for example, by ensuring that new entrants are able to compete for PRO licences in future.