Summarily, it can be concluded that the challenges of electronic waste in Nigeria include, high rate of generation of electronic waste due to prompt obsolence of product designs and importation of e-waste into the country, improper e-waste management practice in the informal sector bringing about pollution of the environment (soil, surface/ground water, air) and its associated adverse health impact on the citizens and in-effective regulatory framework.
Requisite to appropriate waste management in any waste stream is the need to develop appropriate policies and regulations to define expectations, provide guidance and directions for the generators as well as other stakeholders associated with the waste stream. To transition e-waste management practice from the current approach to the ideal situation, the Nigerian Government developed the National Environmental Regulations of 2009 SI No 28, which states that “it shall be the responsibility of producers to incorporate environmental concerns in the design, process and disposal of a product.” In 2011, the National Environmental (Electrical/Electronic Sector) Regulations, 2011 SI No 23 was also gazetted. Regulation 11(1) of that regulation stated that every importer, exporter, manufacturer, assembler, distributor, and retailer, of various brand of EEE products, shall subscribe to an Extended Producer Responsibility (EPR) Programme, including the Buy Back as specified in Schedule VIII of that regulation.
Regulation 11(3) requires that “Manufacturers and Importers of EEE shall partner with the National Environmental Standards and Regulations Enforcement Agency (NESREA), on the Extended Product Responsibility Programme, within 2 years of commencement of these regulations in order to achieve the Buy Back within the period of 2 years”. To provide clarity and direction on the implementation of the EPR Principle, an EPR guideline was developed by the Agency in 2014. This guideline brought the concept of EPR home, allocating roles and obligations to everyone and help all to see that waste management is a collective responsibility. The EEE regulation introduced the EPR principle in Nigeria, hopeful that the Nigerian environment will achieve objectives of decreased total environmental impact from products, by making the manufacturers of products responsible for the entire lifecycle of the product and especially for the take - back, recycling and final disposal of the product.
In practice, what does this mean for the Nigerian EEE sector? It requires that all who manufacture, assemble, or import EEE must take responsibility for their products when they are no longer functional. Tracking products from the moment they are purchased to when they are non-functional can be a challenge for a Producer. To ensure that Nigerian Producers can effectively fulfil this obligation, an industry led approach was adopted. This approach requires that Producers collectively pool resources based on their market share and coordinate the collection and recycling of their products in a cost-effective but environmentally sound manner.
This brought about the incorporation of E-waste Producer Responsibility Organization of Nigeria (EPRON) in March 2018. The organization began operations in May 2019 with the support of responsible organizations like HP and MTN and some environmental enthusiasts; Professor Percy Onianwa and Mr. Oladimeji Oresanya. EPRON is the industry led Producer Responsibility Organization (PRO) for the sector. The role of EPRON is to drive collective compliance to the regulation. Where one and all will contribute their funds according to the market share and this will be used to ensure the environmentally sound disposal of end of life EEE.
With concerted effort, eight Producers have signed on to EPRON namely: MTN Nigeria, Technology Distributions Ltd., ZTE Nigeria, Deltacom Group, IHS Nigeria Ltd., ATC Nigeria Ltd., Corporate Systems Ltd., PA76 Ltd. Two Government accredited recyclers: Hinckley Recycling Associates and E-Terra Technologies have registered with EPRON, providing a channel for environmental sound management of e-waste.
While we patiently wait for more producers to subscribe to the scheme with the June 2020 deadline specified by NESREA in view, the Board and management of EPRON are actively promoting initiatives to raise awareness on the hazards of e-waste especially the dangers of its indiscriminate disposal. We are positioned strategically to benefit in different ways from the Global Environment Facility (GEF) funded project titled: “Circular Economy Approach for the Electronics Sector in Nigeria” being implemented by NESREA as the platform to connect the dots in the EEE value chain. We have collaborated with relevant agencies including: NESREA, Federal Ministry of Science and Technology, Federal Competition and Consumer Protection Commission (FCCPC), Standard Organization of Nigeria (SON), Nigeria Custom Service (NCS), Registered Recyclers, Manufacturers Association of Nigeria (MAN), National Association of Scrap and Waste Dealers Employers of Nigeria (NASWDEN), United Nation Industrial Development Organization (UNIDO), United Nation Environment (UNEP) etc to set up the Advisory Council of EPRON.
This advisory council will work with the Board to determine the treatment costs of hazardous fractions, determine minimum collection incentives, set recycling targets for each period, identify all key stakeholders that must be carried along and create shared value, define collection and recycling standards, enterprise development, education and awareness, developing initiatives to drive compliance and enforcement.
We have succeeded in ensuring the environmental sound recycling of 140 box cathode ray tube televisions and monitors confiscated at the Ports in an environmentally sound manner.
CRT Boxes Management Process Witnessed by all the Relevant Stakeholders
Over the months, one thing that clearly resonates is the fact that e-waste management is a collective responsibility and despite the best intentions of a particular party, nothing can be achieved in isolation. All parties must be very clear about their obligations and they must be committed to fulfilling it.
The role of the National Government in environmental protection include reasoning out international conventions and treaties as well as policy making to the powering agencies, developing appropriate legislation and educating communities. Also critical is the enforcement of legislation and implementation of good environmental practices alongside provincial authorities. Appropriate regulations have been developed to ensure e-waste is managed effectively and over the past years numerous channels have been explored to create awareness on the existing regulations. However, NESREA needs to consolidate her past and ongoing efforts with an appropriate enforcement plan. This will include developing relevant sanctions for defaulting Producers and notify them of the sanctions ahead of the deadline in June. This will serve as a deterrent to defaulters and also serve as an incentive to complying Producers to remain on track.
Producers on the other hand need to acknowledge that it is in their best interest to subscribe to the sector registry and work with other Producers to ensure that e-waste is collectively managed in a cost effective and transparent manner. Informal collectors should focus on collecting e-waste and deposit them in the specified recycling channels and put an end to the crude recycling practices. Consumers would need to comply with upcoming e-waste disposal strategy dropping e-waste in all the specified collection or take back centres, thereby putting an end to comingling of e-waste with other municipal solid waste.