Key business messages. Sustainable Materials Management

Transcription

1 Key business messages Sustainable Materials Management OECD Glbal Frum Mechelen, Octber 2010 BIAC appreciates the pprtunity t participate in the OECD Glbal Frum n Sustainable Materials Management (SMM), which will be held in Belgium n Octber BIAC has been an active participant in OECD wrk in this area and fully supprts the transitin twards a mre sustainable and resurce-efficient ecnmy. An integrated strategy n the sustainable management f bth primary and secndary resurces is necessary t achieve prgress. Business needs t be an integral part f these discussins and lks frward t wrking further with the OECD t assist with plicy develpments in the future. BIAC prpses that the fllwing areas be given due cnsideratin in rder t mve SMM frwards: 1. Establish a clear knwledge base t wrk frm 2. Fster integrated plicy appraches 3. Encurage research and innvatin 4. Optimise plicy instruments 5. Avid a strict target based-apprach 6. Facilitate access t primary and secndary resurces 7. Wrk twards clsing material lps 8. Create a level playing field Business and Industry Advisry Cmmittee t the OECD Tel. +33 (0) /15 Chaussée de la Muette Fax +33 (0) Paris biac@biac.rg France

2 1. Establish a clear knwledge base t wrk frm The OECD has already cntributed greatly t imprving ur understanding f SMM and has rganised several meetings which served t enhance ur knwledge base and cmmn understanding f SMM. BIAC recmmends that this wrk be cntinued t ensure that a clear understanding f the extent f the challenges t be addressed is acquired thrugh all areas f sciety. Tpics t be addressed include, but are nt limited t: the glbal availability f resurces; the need t imprve statistics n bth primary and secndary resurces, paying special attentin t data n imprts and exprts f materials fr manufacturing and the materials cntained in manufactured gds that are traded, as well as catalguing trade flws f secnd hand gds, wastes and scrap; key trends n the use f resurces; skills and capacity; and plicy bstacles. Plicy makers, business and sciety at large need t be clear abut the challenges ahead and what we are trying t achieve thrugh SMM. The OECD Glbal Frum n SMM prvides a key pprtunity fr an exchange f views n the challenges t be addressed. 2. Fster integrated plicy appraches A majr cncern is that SMM culd be seen nly as an envirnmental issue and s nly be integrated int the brad envirnmental agenda, thereby nt meeting its full ptential t address glbal material fcussed issues. Integrating the issue int the mainstream plicy agenda (including thrugh the invlvement f ecnmic, trade and finance ministries) shuld be pursued t ensure that SMM is treated in a cmprehensive manner. BIAC wuld als like t stress that fr SMM plicy t be successful, it needs t fllw a lifecycle apprach that factrs in envirnmental aspects, scial issues and ecnmic csts. It must take int cnsideratin the risk f shift f burdens and recgnise the interdependencies between, fr example, using mre f a specific material in certain applicatins t allw fr savings f anther material in ther applicatins. An integrated plicy n the efficient use f natural resurces is required t bst the availability f natural resurces and clse materials flws. OECD shuld als align its strategy n materials with ther plicy dmains, like energy, climate and agricultural plicy, as this will help t prevent it frm pursuing clashing bjectives and ensure that it always strives fr the mst psitive envirnmental utcme, acting in a cst-effective manner at all times. BIAC recgnises the benefit t highlight the linkages between nging SMM wrk and the OECD Green Grwth Strategy, as there are cmmn factrs between the tw. 3. Encurage research and innvatin Innvatin and technlgy are crucial fr achieving real prgress twards green grwth and shuld be an imprtant crnerstne f any SMM strategy. Business believes that resurce efficiency and SMM shuld be an integral part f research and innvatin strategies wherever pssible. The OECD, thrugh its hrizntal Innvatin Strategy, which was 2 P a g e

3 submitted t the May 2010 OECD Ministerial Cuncil Meeting, has prvided high-level plicy advice n hw t address innvatin requirements in a truly crss-cutting manner. Using innvatin t address key envirnmental challenges, including SMM, shuld be an integral part f future wrk n hw t put these recmmendatins int practice. Greater attentin needs t be paid twards the use f mre efficient resurces frm the beginning, i.e. the material selectin and design stage, as well as thrugh the subsequent phases f manufacture and prduct use, bearing in mind that it is thrugh the creatin and spread f mdern technlgies and new resurce-efficient prcesses acrss the lifecycle that the biggest psitive changes can emerge. Due attentin needs t be paid t ensuring that prmising research and develpment reaches the market and is translated int cmmercial applicatins. 4. Optimise plicy instruments The nature f SMM has led t a number f sft plicies (like vluntary agreements). BIAC des nt agree with the general statement that these mechanisms are less effective than hard plicies (regulatry instruments, market based appraches). Vluntary agreements can take int accunt the specific characteristics f different sectrs and materials. In BIAC s view, t address a specific envirnmental challenge, all plicy ptins shuld be assessed accrding t their ecnmic effectiveness and envirnmental efficiency, bearing in mind that ptimising the chice f plicy instruments used may differ depending n sectr and regin. The key fcus shuld be n defining the bjectives and the mst effective ways f achieving a mre resurce-efficient ecnmy. Hwever, BIAC wuld like t cautin against the use f excessive hard plicies. This is particularly applicable in the cntext f fragile ecnmic recvery. While business understands the need t advcate imprvements in SMM, the impsitin f verly strict regulatry instruments is likely nt the best way t achieve it. Plicies must strike a balance and shuld encurage SMM where feasible withut the utcme that additinal cst burdens lead t resurces being diverted frm investments in innvatin r frce investment t cuntries where envirnmental regulatin is less stringent. Green taxes which are prly designed r mainly created as a revenue raising measure will nt be effective in wrking twards encuraging SMM. We als need t think abut hw regulatin is used. T ften it can fcus n micrmanaging technical issues rather than encuraging cmpanies t actually make their prcesses mre sustainable. Well-managed businesses shuld see their regulatry charges reduced. There is ptential t ptimise plicy by building n the fundatin f past private sectr SMM initiatives. The varius reasns fr the success and failure f previus schemes culd be utlined. This, with clse invlvement f the private sectr, culd help identify plicy that wuld supprt the future implementatin f SMM practices. 3 P a g e

4 5. Avid a strict target-based apprach The OECD has already carried ut sme analysis n pprtunities and challenges f setting and pursuing targets. In BIAC s view, target-based SMM plicy appraches must be cnsidered with great care as the cncept f resurce efficiency cannt be restricted t a simple numerical target. A lack f sufficient indicatrs frm which t measure SMM plicy has already been identified. Furthermre, restricting the cncept f SMM t a strict numerical figure culd have direct impacts n ther plicy bjectives. There is a need fr further bjective analysis n the benefits and disadvantages f using targets and what exactly they are designed t measure. A distinctin shuld be made between hard targets, sft targets, vluntary targets, and brader bjectives, and the prs and cns f these in different sectrs and circumstances shuld be carefully analysed. A ne-size-fit-all apprach must be avided, and careful cnsideratin must be given t implicatins n grwth, innvatin and resurce availability in additin t envirnmental cnsideratins. BIAC recmmends that there shuld be a transparent and inclusive discussin, invlving the business cmmunity frm different sectrs, n the prs and cns f targets befre plicy recmmendatins are made. 6. Facilitate access t primary and secndary resurces Our ecnmies are highly dependent n a range f natural resurces, which are essential fr the manufacture f a wide range f prducts. Glbal demand fr natural resurces is rising quickly, and securing access t natural resurces is a key plicy cncern fr many cuntries. Industry-wide cncerns abut raw materials security have been increasing in recent years, as cmmdity prices have becme increasingly vlatile, and access t certain raw materials has becme a serius issue fr a number f businesses. At the same time, market distrtins and unfair trade practices have aggravated the strained market and need t be urgently addressed. Raw materials security is high n BIAC s agenda and has recently been taken up by the OECD Trade Cmmittee, fcusing n the impact f exprt restrictins. A sund investment envirnment fr prducers and pen markets withut trade distrtins are key requirements fr the availability f raw materials in sufficient amunts and qualities at reasnable prices. Scially respnsible explitatin f natural resurces shuld nt be held back by red tape, inefficient regulatin r cmpetitiveness distrtins. SMM als highlights the need t have secure access t secndary resurces (i.e. waste fr recycling). Ensuring raw materials security als requires a well-functining recycling sectr, which is als ften cnfrnted with the impacts f trade distrting measures. Accrdingly, the creatin f fair framewrk cnditins fr all ecnmic actrs invlved in the waste management f prducts (including the manufacturers) is needed t ensure that markets fr primary and secndary materials can perate freely. We need t facilitate a market where cmpanies that cannt reuse their waste can sell it t thse wh can use it. The OECD shuld further encurage its member cuntries t take affirmative actin against 4 P a g e

5 restrictins n exprts f primary materials as well as imprving enfrcement f the rules n exprts f end-f-life gds and wastes under OECD Cuncil Decisin C(2001)107/Final. Finally, BIAC supprts landfill reductin plicies t establish a sund basis fr SMM. As lng as landfills are the reference in a cuntry t discard used prducts, SMM plicies will mst likely fail. The wider ecnmy benefits frm a wrldwide increase in recycling activities. 7. Wrk twards clsing material flws Industry has undertaken majr effrts in clsing material flws. These effrts shuld be supprted by plicymakers wh shuld create an enabling plicy framewrk fr business t engage in efficient prductive prcesses and t clse material lps. Challenges that remain with respect t clsing material flws mre efficiently need t be addressed. Such challenges include, but are nt limited t, lack f available technlgies, regulatry limitatins, and public perceptin issues. Besides landfill reductin plicies, cnsumers and gvernments need t be fully aware f the imprtance f selectively cllecting used items. Fllwing n frm cllectin, the SMM aspects f increasing the refurbishment and reuse f gds as well as ptimising waste flws need further cnsideratin. 8. Create a level playing field SMM perfrmance in nn-oecd cuntries may vary cnsiderably acrss least develped, develping r rapidly industrialising cuntries. Whilst cnsumptin f primary and secndary raw materials, manufactured gds and reused gds in develping and rapidly industrialising cuntries is increasing, the trade in these gds frm OECD t such nn- OECD cuntries can in sme cases raise bth envirnmental prtectin and public health cncerns. There are ften large SMM differences between OECD and nn-oecd cuntries. In this cntext, the OECD culd explre the rle f glbal perating standards t ensure that bth the extractin f primary materials (including preparatin fr use in dwnstream industries) and the recycling f materials (frm cllectin thrugh t placement back int the ecnmic circuit) encmpass the need t prtect the envirnment and public health, while als meeting ecnmic and technical efficiency. Future OECD wrk n SMM BIAC actively supprts fact-based, bjective OECD analysis n SMM. As a multi-disciplinary rganisatin with ecnmic fcus and excellent analytical capacity, the OECD can make a majr cntributin t advancing the knwledge abut the challenges and pprtunities presented by SMM. In BIAC s view, the fllwing areas deserve particular cnsideratin: SMM is currently being addressed in the Wrking Grup n Waste Preventin and Recycling. We encurage the OECD t address SMM in a truly crss-cutting way, 5 P a g e

6 benefiting frm the expertise it has in ther areas, such as trade, investment, taxatin, and innvatin. The OECD has an imprtant rle in fstering the right framewrk cnditins fr pen and prperly functining raw materials markets. This includes fact-based analysis f the range f existing trade distrtins affecting the mvement f raw materials. BIAC welcmes wrk in this area which is nw being undertaken by the OECD Trade Cmmittee. Plicy makers must recgnise the imprtant rle that dmestic recycling industries play in the area f secure supply f raw materials and SMM. The OECD culd help identify barriers, such as the implicatins f waste management riented legislatin and bureaucratic burdens. We als encurage the OECD t share experience in the area f scrap cllectin and recvery structures with key emerging ecnmies. In view f the implicatins that stringent target setting can have, there is a need fr further bjective analysis n the prs and cns f using targets befre plicy recmmendatins are made. Such analysis shuld be carried ut in clse cperatin with industry. T address large SMM differences between OECD and sme nn-oecd cuntries, the OECD culd explre the rle f glbal SMM perating standards fr industry that encmpass the need t prtect the envirnment and public health as well as meeting ecnmic and technical efficiency. 6 P a g e

7 ANNEX Cmments n the case studies submitted by sectr experts Aluminium case study The use f 2006 industry data limits the value f the dcument in presenting the cntemprary aluminium industry. The paper spends cnsiderable effrt and fcus n a cmparisn f tw mdels f the industry - a Eurpean mdel and a Wrld mdel fr bth the refinery and smelter segments f the industry. Hw des this feed int the thesis being develped in the paper and its findings/cnclusins? D the changes in glbal prductin since 2006 impact n the assumptins? The paper shuld cnsider the changes and mvement within the industry in the subsequent three years which are arguably the mst dramatic in terms f structural shifts ever witnessed by the industry (since the fall f the Sviet Unin). The paper fails t cver adequately the subject area f the glbal flw f materials within the aluminium sectr. Fr instance, there is n reference t nepheline which is used as an alternative feed stck (in place f bauxite) fr the prductin f a significant share f the Russian alumina. The paper wuld be mre balanced by the use f the term "bauxite residue" rather than the slang "red mud" (fr example, refer para 3 f the Executive Summary). In the same paragraph "and CO 2 " shuld be added after the wrd "perflurcarbns" fr accuracy. While the aim f the paper refers t prductin and use, the Executive Summary (page 2, para 2) starts t intrduce uncertainty as t whether the paper is dealing with capacity r prductin and this ccurs elsewhere in the paper. The Executive Summary (page 2, last para) appears t verlk ther factrs fr reducing CO 2 within a smelter which d nt cme frm plant/technlgy-based efficiency imprvements but cme frm the intrductin f different ptrm management prcesses. Replacement/retirement f ld plant will als deliver an increment f efficiency t the glbal smelter fleet. Tables 1-3 cvering prductin f bauxite alumina and aluminium demnstrate the prblem f the reliance f utdated material (2006): IAI reprted prductin data cmbined with data reprted by the China Nn-Ferrus Metals Industry Assciatin prvide a guide t hw significant the reginal shift has been since 1996: West Eurpe accunted fr 12.6% f the reprted glbal prductin in 2006 cmpared t 10% in 2009; the Nrth American share declined frm 16% t 13% ver the same (shrt) perid; n the ther hand, China grew frm 28% t 36% - and this year China is prjected t prduce arund 40% f glbal primary aluminium. 7 P a g e

8 This shift has a very material change n the sectr, principally thrugh the energy surce fr the electricity cnsumed in the smelting phase f the prcess. Similarly, n alumina prductin the gegraphic shift will influence the glbal flw f materials and, again, it is the change in China that causes the largest impact n the utcmes: in Table 2 (page 9), China is reprted as prducing 13.7 millin tnnes f alumina accunting fr 19% f glbal prductin in 2006 this cmpares t 23 millin tnnes reprted by CNIA fr 2009 and H1/2010 data suggest an annual prductin arund 28 millin tnnes fr 2010, duble the 2006 level and estimated t be in the rder f 35% f glbal prductin. Sectin Alumina indicates crrectly that nt all alumina is used t prduce aluminium and refers t use in refractry prducts; this culd be extended t refer t metallurgical grade and t chemical grade alumina (arund 5 millin tnnes annual prductin). Sectin makes reference t recent smelter capacity develped in the ME-Gulf regin (referencing 2006 prductin) and smelters being built in Iceland and t the shifts in prductin that culd cme frm the relative cst f energy in different lcatins. This is where the current situatin verwhelms the relevance f the paper and shws the paper t have been develped in a static 2006 wrld withut taking the pprtunity t describe the changes and mvement within the industry in the subsequent three years which are arguably the mst dramatic in terms f structural shifts ever witnessed by the industry (since the fall f the Sviet Unin). Sectin Bauxite Mining (page 13, last para): it is questinable whether bauxite mining requires a large supprt netwrk cmpared with that f ther mining peratins (pen-cut versus undergrund) and the level f verburden is relatively small cmpared with many ther pen-cut mining peratins. Sectin Alumina Prductin (page 17, para 1, bullet 1) add the wrd slutin after caustic sda Figure 7 (page 22): the inputs d nt ttal ne tnne and thus d nt create ne tnne f ande; it is nt clear what sea water is used fr in the prductin f andes under the Wrld mdel; als, the difference in the level f steel inputs shuld be reviewed, alng with the levels f slid waste (landfill) frm the tw alternative mdels (5.3 kg vs kg). Figure 11 (page 26) Ande paste is misleading and culd just read Ande. Sectin Industry Perfrmance Gals (page 34): It is suggested that the paper shuld reprt perfrmance against the gals established by the IAI. Our mst recent reprts are available n ur website. Table 6 (page 38): fr China, the apparent cnsumptin f aluminium in China is nw in the rder f kg per capita (up frm the 6.63 kg shwn in Table 6 fr 2006, reflecting the significant changes ver the last few years. Additinal detailed cmments frm IAI were submitted t the OECD Secretariat. 8 P a g e

9 Cmments n the wd fibres case study CEPI members are very interested in the SMM apprach, and in particular the suggestins fr SMM made by the Belgian presidency f the EU Envirnment Cuncil n 13 July 2010 in Ghent, aiming at the efficient and respnsible use f materials and calling fr remedy f the current fragmented plicy structure n waste, natural resurces, raw materials, integrated prduct plicy, ec-design and sustainable cnsumptin and prductin, as well as better integratin f SMM with ther plicy areas. In cntrast, the OECD reprt n Wd Fibres des nt seem t reach the same level f visin and fcuses primarily n the past instead f aiming twards the future. CEPI wuld like t make the fllwing general remarks abut the study: Scpe, system, prduct grup and functinal units: Despite the title Wd Fibres, the study fcuses n the pulp and paper industry nly, mitting the fibre flws in ther industries and between thse industries. In additin, the study has nt defined any functinal units, withut which all input, utput and envirnmental impact lse significance. T avid this, SMM shuld be clsely aligned with life-cycle management and LCA methdlgy as develped by the EU and UNEP. The study may als benefit frm a clarificatin f its scpe and system bundaries. Data: Data is ften ut f date. Envirnmental aspects: Envirnmental crss-media effects are nt cnsidered, e.g. clsing the water lp is likely t increase the need fr energy and chemicals, as well as impact ccupatinal health and safety aspects. Water definitin: Water use is measured in the study as intake when the impact f water cnsumptin wuld be mre apprpriate. Hypthesis and rbustness: The study suggests "substantial pprtunities, hwever, these pprtunities are nt assessed systematically but seem t be picked subjectively frm varius surces. Impacts are nt assessed nr is there a verificatin f the status as t whether the listed technlgies are actually available r cmpatible. On the ther hand, it is nt clear what the pprtunities culd be in Eurpe where, fr example, 94% f the paper mills already apply CHP technlgy. In additin, the study cncludes rather bscurely by stating weak enfrcement f regulated practices. We can see n supprt f this in the dcument and disagree with such a statement since the paper industry is ne f the mst regulated sectrs in Eurpe and cmplies with its legal bligatins. The Eurpean paper industry is, hwever, willing t supprt the develpment and active implementatin f a plicy framewrk based n the SMM apprach, cvering the full lifecycle f prducts and manufactured gds, frm the harvesting f raw materials t prduct design, manufacture, cnsumptin and end-f-life, frm cradle t cradle. Here SMM can be an apprach fr the efficient and envirnmentally respnsible use f materials, independent f whether they are raw materials, prducts r waste. 9 P a g e

10 Cmments n the plastics case study Scpe and Objectives f the Plastics Case Study: In general, the case study fcuses n end-f-life issues instead f the full life cycle. The study is limited in that it excludes a majr plastics market segment packaging. The study des nt include an analysis f the use phase f plastics in the life cycle, which needs t be included alng with a feedstck analysis. The sustainability benefits and sustainable materials management analysis f plastics in many cases are reflected in the use phase. Full life cycle and sustainability findings fr plastics as fr sustainable materials management A cmprehensive prduct sustainability reprt cnducted in June 2010 n plastics (Surce: The Impact f Plastics n Life Cycle Energy Cnsumptin and Greenhuse Gas Emissins in Eurpe, Denkstatt GmbH, Hietzinger Haupstrasse 28, 1130 Vienna, Austria, prepared fr Plastics Eurpe by authrs Harald Pilz, Bernd Brandt, Rland Fehringer) cvered ver 85% f all plastics applicatins in Eurpe (173 plastic prducts in 32 case studies) with a fcus n energy use and climate change effects frm the whle life cycle f the prducts assessed. The study fllwed the principles f ISO and was peer reviewed by tw independent reviewers. Key findings are as fllws: Overview f Denkstatt Study The study included 173 plastic prducts acrss all plastic applicatins in Eurpe 46 millin tnnes f plastics were cnsumed in the EU 27+2 in 2007 The study examined energy used thrughut the entire life cycle f the plastic prducts Packaging prducts examined: milkshake and cream cntainers, a cndensed milk prtin pack, a liquid washing agent bttle, a jam catering pack and a still mineral water bttle. Plastics meet sciety s needs better than the materials they replace. Substitutin f plastics where feasible (based upn 2007 scenari) wuld: Generate 3.7 times mre mass (impacting waste management) Result in 61% mre GHG (greenhuse gas emissins) Lead t 57% mre energy being cnsumed Plastics and energy efficiency results include: 10 P a g e

11 Plastic prducts enable energy savings f millin GJ per year equating 50 millin tnnes f crude il that is 194 very large il tankers Plastic prducts prevent GHG emissins f 120 millin tnnes per year which equals the ttal CO2 emissins f Belgium (in 2000) r 38% f the EU15 Kyt target n the reductin f GHG emissins The carbn ftprint f an average EU 27+2 cnsumer amunts t abut 14 tnnes CO2 per capita, a mere 1.3% - r 170 kg stem frm plastic prducts Substituting plastic prducts with alternative materials wuld increase energy cnsumptin by 57% (acrss the ttal life-cycle f plastic prducts) and increase greenhuse gas emissins by 61% Plastics packaging and energy efficiency results include: Apprx. 190 millin tnnes f CO2 emissins can be saved thrugh plastic packaging Only 1 t 3 % f the weight f a packaged prduct cmes frm plastic packaging Plastic packaging saves 27 millin tnnes f il that wuld be cnsumed if heavier alternatives were used. This equates the crude il cnsumptin f the entire Belgian and Dutch car fleet (25 millin cars) Packaging is the applicatin where plastics allw fr the highest energy savings Cmpared t alternatives, plastic packaging applicatins nt nly need less energy during the prductin phase but als enable significant energy savings during the use phase Wrapping fresh fds in plastics instead f alternatives prevents 10% f fd lsses and saves a further 22 millin tnnes f CO2 emissins. Plastics efficient use f il and natural gas Eurpe Plastics prductin accunts fr just 4% f il and gas use Remaining 96% f il and gas use are: Transprtatin 45% Heating, electricity and energy prductin 42% Chemical and petrchemicals industry 5% Other nn-energy uses 4% United States (Surce: U.S. EIA Energy Infrmatin Administratin) Plastics prductin accunts fr 4.6% f ttal U.S. petrleum prductin (liquid petrleum gases LPG; and natural gas liquids NGL) In additin, 1.5% f ttal U.S. natural gas cnsumptin were used as feedstck A carbn balance f the ttal plastics market in the EU27+2 shws that the estimated use phase benefits (reductin f GHG emissins enabled by plastics prducts) were rughly 5-9 times higher than the emissins frm prductin and recvery f all plastics in P a g e

12 The ptential fr increasing the use benefits up t 2020 is much higher than the additinal emissins frm the grwth f plastics. In 2020 the estimated use benefits culd be 9-15 times higher than the emissins frm prductin and waste management in This carbn balance shws the huge imprtance f prper understanding f the s called interdependencies. Cnclusins The plastics case study des nt fully capture the full life cycle and use phase analysis f plastics Cmprehensive life cycle study (Denkstatt reprt) demnstrates sustainable materials management f plastics in numerus applicatins An integrated strategy n the sustainable management f bth primary and secndary resurces is a key element f SMM plicy that OECD shuld incrprate plastics demnstrate SMM thrughut its life cycle and value chain and clearly shw the material interdependencies, therefre a brad hlistic apprach is a must in SMM. 12 P a g e

13 Cmments n the Critical Metals and Mbile Devices case study BIAC acknwledges the cnsiderable effrts made in cmpiling the Critical Metals and Mbile Devices Case Study and the wealth f data cntained therein. Since the study was published in its current frm, the EU has brught frth a list f 14 critical materials illustrated belw, BIAC reiterates the EU industry cmments after that publicatin that such a list will change with time and circumstance and s studies n determining critical materials shuld be repeated at intervals. Cnsideratin f What makes a Critical Metal? demnstrates inter alia the need fr SMM plicies t be cmplimentary and cherent with trade plicies. The OECD Trade Cmmittee wrk n Exprt Restrictins and Trade in Raw Materials is imprtant in that respect. As studies by the OECD carry much authrity, the fllwing few edits are requested in rder t maintain the quality f the case study: Paragraph 41, last sentence shuld be deleted as it is nt cherent with later sectins n recycling nr with the ther SMM case studies shwing the envirnmental benefits f recycling plastics and aluminium. Paragraph 82, 3 rd sentence, shuld be deleted as it is unreasnable t state manufacturers shuld be held accuntable fr material r metal selectin decisins in their prducts based n the risks frm illegal practices in the infrmal recycling sectr. Paragraph 47, Paragraph 83 and Figure 19 appear t cntradict in determining the dminant phase, whether cmpnent manufacture and assembly r use. 13 P a g e