Reprocessing e-waste

E-waste reprocessors accept a diverse range of used electronic waste, using a variety of methods to recover these valuable materials. Both e-waste and processed e-waste materials must be handled and stored with due care to avoid leakage and the release of hazardous substances into air, water or soil.

Specified e-waste poses a greater environmental and human health risk than other types of e-waste. More controls are required to store, handle and recover materials safely.

This information is about understanding your risk and putting in place controls to eliminate and/or minimise risk to human health and environment from reprocessing of e-waste in Victoria.

Who this information is for

This information is for businesses that reprocess e-waste. Reprocessors alter the physical state of e-waste. This includes manual dismantling, shredding, crushing or compacting, thermal treatment, hydrometallurgy and other forms of e-waste treatment.

Why you have to take action

The poor management of e-waste poses a hazard to the Victorian community and environment. The primary risks from e-waste reprocessing are the impacts of air emissions, dust, ground contamination from e-waste liquid components, and fire.

Risky e-waste stockpiling may also result in the increased likelihood of fire and soil contamination. As some persistent organic pollutants, dioxins and polycyclic aromatic hydrocarbons (PAHs) are released as combustion by-products of e-waste, the consequences of fires at e-waste reprocessing facilities could be substantial.

The Victorian Government has banned e-waste from landfill in Victoria, effective 1 July 2019. You have to understand and control your risks to human health and the environment from that date.

What you need to do

Businesses that reprocess e-waste must:

understand the risks of harm to human health and the environment posed by e-waste and communicate this to staff
store, transport and handle e-waste to eliminate or reduce risk of harm to human health and environment, including fire risk
maximise material recovery
keep records for the movements of e-waste
keep records of e-wastes materials through to point of usable material or disposal
document the assessment of downstream processors or vendors of e-waste, process materials and residual waste
support upstream providers to ensure e-waste is received in a way that minimises risk of harm to human health and the environment.

Storing and transporting e-waste

Where there is a risk, storing e-waste on an impermeable surface and protected from the weather, can help control dust particles and run-off being released that could contaminate land, surface water and groundwater.

Specified e-waste must be stored on an impermeable surface and protected from the weather.

According to the Environment Protection (Scheduled Premises) Regulations 2017, ‘specified electronic waste’ means:

rechargeable batteries
cathode ray tube monitors and televisions
flat panel monitors and televisions
information technology and telecommunications equipment
lighting
photovoltaic panels.

All e-waste streams at your site should be assessed for risks to determine any necessary controls. For example, you may identify that bunding is required to manage the risk of ground contamination from e-waste liquid components, including heating and cooling equipment or batteries. See Liquid storage and handling guidelines (publication 1698) for more information about how to eliminate or reduce the risk of contaminating land, surface water and groundwater.

At a minimum, you need to ensure that e-waste loads are secure before transporting. You must also minimise damage or breakage. There are additional requirements for packing and transporting lithium batteries, see Australian Code for the Transport of Dangerous Goods by Road & Rail.

Disposal of smoke detectors and smoke alarms

Smoke detectors and smoke alarms should not be crushed, shredded or dismantled in anyway as some contain a small amount of radioactive material. Domestic smoke alarms can be disposed in normal household rubbish. Disposing of smoke alarms in normal domestic rubbish does not contravene the e-waste disposal requirements. For more information see the Q&A about e-waste.

Maximising material recovery

Businesses that reprocess e-waste must maximise recovery of output materials and minimise the amount of residual waste from the e-waste.

Where compacting, crushing or shredding occurs, appropriate isolation and engineering controls must be in place to manage the risk of harm to human health and the environment. This may include a dust collection system/apparatus. Relevant administrative controls, for example clear labelling of assemblies, components, and parts, and personal protective equipment should also be implemented.

Aggregated specified e-waste must not be deliberately crushed or shredded unless there are controls appropriate to the risk. The crushing and shredding of specified e-waste is likely to release a dust with hazardous properties. Many specified e-wastes contain lithium batteries that could cause a fire if damaged during crushing or shredding.

Crushing and shredding of other e-waste, such as whitegoods, may be acceptable provided there are relevant controls to address other risks including dust amenity, battery fires and liquids components (e.g. heating oils, coolants).

Keeping appropriate records

There are a number of record keeping requirements for e-waste reprocessors. These are specified in the Waste Management Policy (E-waste) (PDF 133KB).

Businesses that reprocess e-waste must keep records of:

each load of specified e-waste accepted
total e-waste flows per financial year
total material recovery rate per financial year
compliance with material recovery standards.

Evidence of recovery arrangements for e-waste can be demonstrated by receipts/invoices from a compliant downstream vendor or processor of materials recovered from e-waste.

All required records must be kept for a minimum of 5 years. These records allow EPA to cross-check records of specified e-wastes loads to ensure they are being received at the appropriate e-waste service provider.

Controlling hazards and risks

Any person that is responsible for e-waste must assess the risks of harm to human health and the environment and take steps to eliminate or manage the risks.

Find out more about controlling hazards and risks.

More information on e-waste reprocessing

The information below is designed to help businesses that reprocess e-waste as part of their processing and/or recycling operations understand EPA’s licensing requirements.

There are legal requirements for the reprocessing of specified e-waste. These requirements assist in supporting legitimate and sustainable e-waste recycling opportunities in Victoria.

Premises with the capacity to reprocess more than 500 tonnes of specified electronic waste per year are scheduled premises.

Q&A about reprocessing e-waste

I reprocess e-waste. What should I do and what EPA approvals do I need?

E-waste must be reprocessed and stored in a way that minimises risk and hazards to human health and the environment. EPA recommends that a management plan for the reprocessing of e-waste be developed and implemented to ensure that excessive amounts of e-waste are not accumulated.

Existing businesses that reprocess more than 500 tonnes of specified electronic waste per year must have an EPA licence for their premises.

Existing businesses that reprocess less than 500 tonnes of specified electronic waste per year must understand and control their risks to human health and the environment.

New businesses that do not currently reprocess e-waste, but are proposing to reprocess more than 500 tonnes of specified e-waste per year, need to apply for a works approval (to establish the site) from EPA, prior to applying for a licence (to operate). The works approval guidelines outline the assessment process and how to prepare your application.

Businesses that are planning to receive crushed e-waste may also need to apply for a works approval and licence for PIW Management (A01). Prescribed industrial waste is determined in accordance with the Environment Protection (Industrial Waste Resource) Regulations 2009. For more information, contact EPA’s Licensing Team on 1300 372 842 (1300 EPA VIC).
What if I don't have a licence?

The maximum penalty for operating without a licence is 2400 penalty units (approximately $395,000 in 2019–20), with additional penalties for ongoing operations. The Environment Protection Act 1970 specifies penalties for operating a site without a licence, and for breach of licence conditions.

For more information on the licence application process, contact EPA’s Licensing Team on 1300 372 842 (1300 EPA VIC).
Do I need to be certified with AS/NZS 5377?

The Environment Protection (Scheduled Premises) Regulations 2017 do not require e-waste reprocessors to be certified under Australian Standard/New Zealand Standard 5377:2013 Collection, storage, transport and treatment of end-of-life electrical and electronic equipment (AS/NZS 5377).

Every site is expected to comply with the Waste Management Policy (E-waste) (PDF). Risks vary from site to site, including the amount of e-waste managed on site and the activities undertaken. It is your responsibility to know what is most appropriate for your risks.

Please refer to clause 8 of the Waste Management Policy (E-waste) with respect to compliance with the Policy and the Standard.
What chain of custody records are required?
As outlined in the Waste Management Policy (E-waste) (PDF), records are required for the movement of e-waste. For example, reprocessors of e-waste must record the following information for each load of specified e-waste received at the premises (amongst other requirements):
- The name and address of the premises from which the specified e-waste is transported.
- The date of receipt of the incoming load.
- A description of the specified e-waste.
- The quantity of the specified waste.
Reprocessors must also record the following information for each financial year:
- The description and weight of incoming e-waste.
- The type of processes used to reprocess e-waste.
- The description, weight destination and output materials and residual waste (amongst other requirements).
- EPA can request these records to follow e-waste and understand the flow of e-waste material through to resource recovery.
When is an object considered to have lost its physical integrity? If e-waste is broken, is it non-compliant?

Broken e-waste is not automatically non-compliant with the Waste Management Policy (E-waste) (PDF). It’s possible that some e-waste items will be broken even with good management.

Manually or mechanically crushing or shredding e-waste increases the risk of harm to human health and the environment because of potentially harmful dust emissions. Where significant breakage is likely to occur, measures to control harm must be considered.
How do we manage an increase of plastic waste at our site?

Combustible recyclable and waste materials (CRWM) at resource recovery facilities must be managed in accordance with the Waste Management Policy (Combustible Recyclable and Waste Materials). Duty holders need to ensure they also manage this waste stream accordingly to reduce risks such as fire.

The Management and storage of combustible recyclable and waste materials – guideline (publication 1667) was developed to help duty holders understand their compliance obligations.
What should members of the public do if they’re concerned about a site that is, or may be, storing lots of e-waste?

If you are unsure about stockpiling operations of a site, you can report it to EPA on 1300 372 842 (1300 EPA VIC). The dumping of e-waste is also an offence under the Environment Protection Act 1970, and can attract significant penalties.
How do I dispose of household smoke detectors?

Domestic smoke detectors must be disposed of to landfill in the normal domestic rubbish. Domestic smoke detectors must be trickle fed into the domestic refuse waste stream (no more than 10 at a time, per bin).
Can smoke detectors be reprocessed?

Smoke detectors must not be crushed, shredded or dismantled in any way as they contain a small amount of radioactive material.

Complete household domestic smoke detectors present no radiation risk to the public or workers. Any domestic smoke detectors must be disposed of to landfill in the normal domestic rubbish (no more than 10 at a time, per bin).

If your business has, for any reason, crushed, shredded, or dismantled a household smoke detector please contact the DHHS Radiation Safety Team on 1300 767 469.

When the domestic smoke detector is a type designed for battery replacement, the batteries can be removed from an undamaged smoke detector. Batteries from a domestic smoke detector should be disposed following the advice from Sustainability Victoria.

Q&A about reprocessing or recycling e-waste

What are the streams of materials that are produced from the recycling or reprocessing of e-waste?
When e-waste is recycled or reprocessed it results in three streams of materials being produced. These are:
- E-waste from larger e-waste items that requires further reprocessing, such as light globes from a lamp or batteries from a mobile phone.
- Output materials suitable for reuse or recycling (other than e-waste). An example would be when a commercial dryer is stripped, the scrap metal components would be considered output materials.
- Residual waste materials arise from reprocessing which are not suitable for recycling and need to be disposed of such as certain types of plastics.
At what point in the recycling or reprocessing of e-waste is it no longer considered e-waste?

E-waste is no longer considered e-waste when it has been reprocessed and sorted into either residual waste or output materials that do not contain electrical, or electronic equipment.
How do I need to manage the output materials on site?
After the reprocessing of e-waste, duty holders must classify output materials (other than e-waste) in the following ways:
- Output materials suitable for reuse without further reprocessing or recycling.
- Output materials that require any further reprocessing or recycling will be classified as follows:
  - industrial waste
  - prescribed industrial waste.
As with all wastes, it is the responsibility of the Duty Holder to understand the requirements and undertake the relevant sampling or due diligence to ensure the waste streams are handled and disposed of in accordance with the Environment Protection Act 1970 together with EPA Regulations and waste management policies.

Further information regarding the hazards associated with reprocessing e-waste can be found in Regulatory Impact Statement – Proposed Environment Protection (Scheduled Premises) Regulations 2017 (publication 1639); section 4.2.3 E-waste reprocessing, Table 5: Hazardous e-waste elements and persistent organic pollutants.
What is industrial waste?
Industrial waste is defined in the Environment Protection Act 1970 as follows:
- any waste that arises from commercial, industrial or trade activities or from laboratories
- any waste-containing substances or materials which are potentially harmful to human beings or equipment.
This includes things like clean glass or uncontaminated plastic.

For more information see:
- How to manage industrial waste.
- Industrial waste resource guidelines (IWRG).
What is prescribed industrial waste?

Wastes generated from commercial or industrial activities that are potentially hazardous to humans or the environment require a higher level of control and are called prescribed industrial wastes (PIW). This includes things like crushed lead glass.

These wastes are regulated under the Environment Protection (Industrial Waste Resource) Regulations 2009.

Prescribed industrial waste requires a waste transport certificate to be transported.
How can I tell if my waste is prescribed industrial waste?

EPA uses prescribed industrial wastes (PIW) classifications.

More information on how to determine whether your waste is PIW can be found in the industrial waste resource guidelines (IWRG).

Looking at the manufacturing information of the e-waste you are reprocessing or recycling may help you determine if some of the materials, such as the plastics, are PIW. In other cases, the waste may need to be tested to determine if your waste is PIW. If you need more advice, you may need to engage an environmental consultant.
I own an e-waste recycling facility. Am I responsible for working out if my waste is prescribed industrial waste?

Yes. As a business owner, it is your responsibility to understand your waste and undertake the relevant sampling or due diligence to ensure the waste streams are handled and disposed of in accordance with the Environment Protection Act 1970 together with EPA Regulations and waste management policies.

Please also note that you are required to classify and manage your waste and maintain records to support the classification and management in accordance with the Waste Management Policy (E-waste) (PDF).
Is there any obligation for storage of materials on site?
The Waste Management Policy (E-waste) (PDF) requires that e-waste must only be stored for the purpose of transferring, recycling or reprocessing. E-waste service providers must also take all reasonable steps to minimise the duration of storage of e-waste under their control or in their possession.

It is advised that e-waste service providers should also store output materials separately to unprocessed e-waste. This will make it easier for you to differentiate unprocessed e-waste and output material volumes.

The Waste Management Policy (E-waste) requires that a person must take all reasonable steps to reduce the risk to human health and the environment from e-waste. Accordingly, reasonable steps must also be taken to:
- prevent breakage or spoilage of e-waste that might limit its suitability for reprocessing
- provide e-waste to an e-waste service provider who complies with this policy.
EPA has developed guidance to assist with storage of some output materials. This includes:
- Management and storage of combustible recyclable and waste materials – guideline (publication 1667) – a practical guide on how to comply with the waste management policy.
- Liquid storage and handling guidelines (publication 1698).
- Storing e-waste.
Do I have to recover or recycle as much of my e-waste as possible?

Yes, the Waste Management Policy (E-waste) (PDF) requires that businesses that recycle or reprocess e-waste must maximise recovery of output materials and minimise the amount of residual waste from the e-waste.
How can I demonstrate that the controls I have on my site are effectively managing risks? What evidence can I provide?
The guidance above outlines the key steps for managing risk, including checking controls are effective and appropriate. There are a number of ways to show that you have effectively managing your risks. These could include:
- a risk assessment, which includes hazards, controls and residual risks
- a timeframe for implementing the controls identified on the risk assessment
- an environmental or engineering report that assesses risk and/or determine the most appropriate controls
- evidence of reviewing hazards and risk assessments regularly as these can change over time
- evidence of regular reviews, testing and maintenance of all engineering controls
- regular site inspections and audits
- inspecting, testing and maintenance of risk control systems
- an emergency management plan.
More information on some of the ways you can demonstrate your controls are effectively managing risks can be found in Assessing and controlling risk: A guide for business (publication 1695)