The EEE sector is highly diverse, with products ranging from consumer-facing electronics like mobile phones and TVs, to large industrial cables installed underground. The challenges faced are unique to each product category and solutions must be tailored to meet the specific needs of different product groups.

This sector is the 3rd largest consumer of plastics in Norway, at ~71,000 tonnes in 2020, and is the 4th largest source of plastic waste, accounting for ~38,000 tonnes of waste.

The inappropriate handling and treatment of WEEE represents a serious environmental, social, and economic threat. There have been a number of regulatory attempts to alleviate these challenges, including the European WEEE Directive, introduced in 2003 and revised in 2012 with the aim of maximising the recovery of valuable resources through reuse and recycling, and reducing environmental impacts caused by inappropriate treatment, littering and leakage into nature.

The inappropriate handling and treatment of WEEE represents a serious environmental, social, and economic threat. There have been a number of regulatory attempts to alleviate these challenges, including the European WEEE Directive, introduced in 2003 and revised in 2012 with the aim of maximising the recovery of valuable resources through reuse and recycling, and reducing environmental impacts caused by inappropriate treatment, littering and leakage into nature.

The Directive requires each country to collect 85% of waste generated at dedicated collection facilities (or 65% of put on market volumes). According to a recent study by the United Nations Institute for Training and Research (UNITAR)¹⁶, Norway separately collects around 70%-80% of its WEEE. It is therefore non-compliantⁿ with the Directive, but is nevertheless one of the leading European countries in terms of WEEE collection. However, this means that 20%-30% of WEEE is not collected via the formal system, representing a leakage in the system and reducing the probability of material recovery.

The main reasons for leakage are:

• Norway having a large informal sector, which accounts for around 20% of the leakage, involving the theft of WEEE from collection points which is then typically exported illegally, predominantly to Eastern European and African countries¹⁵.
• Industrial cables remaining uncollected at end-of-life due to the high costs of recovery.
• Incorrect disposal of WEEE in mixed waste, which significantly reduces the chance of recovery.

It is also likely that collection rates are even lower than estimated in this study given that the data on theft is highly uncertain and could be significantly underestimated, particularly for higher value small items such as mobile phones, which also typically have the highest of plastic content.

ⁿ However, it should be noted that Norway’s WEEE directive covers a wider scope compared to the rest of the EU, including large industrial cables and large industrial equipment. Excluding these categories would mean that Norway is compliant with the directive, achieving collection rates of 85%-91% of total WEEE generated.

Despite its comparatively well-established collection network, the Norwegian EEE plastic system is 69% linear with less than 1% of WEEE reused and 30% of WEEE plastics recycled annually.

Following collection and sorting, WEEE undergoes disassembly and depollution share, shredding and mechanical sorting in specialised treatment facilities. Recycling of WEEE plastics is a well-established part of the treatment process, with sink-float tanks used to separate and sort polymers and to remove and selectively treat plastics containing brominated flame retardants listed under the European POP (persistent organic pollutant) and REACH legislation which cannot be put back on the market. There is

also no recycling of certain polymers, such as PVC, due to additive content and/or a lack of market for recyclates. This leads to average yields of around 60%-70% ¹⁷.

Repair and reuse of EEE is currently an underutilised opportunity. Today, many goods are discarded despite being fully operative or easily reusable if fixed. There is also no system in place to identify and recover reusable products once they are collected as WEEE. Therefore, there is great potential for scaling the secondhand market in Norway by creating demand for secondhand products and establishing a collection system able to separate reusable goods.

Current WEEE regulations lack focus on the recovery of plastics and upcoming policy could even risk a reduction in plastics recycling from WEEE.

The WEEE Directive focuses primarily on collection and overall material recycling rates but lacks focus on the recycling, reuse or recovery of plastics from WEEE. There is even a risk that upcoming policy will have adverse effects on plastics recycling from WEEE due to more stringent constraints on POPs, which could be detrimental to WEEE plastics recycling. Furthermore, there have been signals indicating the potential removal of large industrial equipment and large industrial cables from the Norwegian WEEE Directive as these are not included in the EU WEEE Directive.

• A lack of design for recycling of EEE, specifically with regards to plastics.
  • Many polymers are still being used which are not recoverable by current sorting techniques due to overlapping densities with polymers containing substances of concern.
  • The use of additives and composite materials that alter the densities of polymers, making sorting challenging.
  • The high level of heterogeneity of WEEE plastics, with a varying composition of polymers from sample to sample raising the cost of recovery and lowering the yields achieved.

• Relatively low costs of disposal compared to the costs of mechanical sorting and recycling, creating incentives to landfill or incinerate the plastic components rather than recycle them.

• Low quality of recyclates leading to downcycling, mainly for lower value applications such as outdoor furniture and plant pots¹⁷.

EXHIBIT 17

As % of total demand for utility (with deduction of stock)

* corrected for net addition to stock
**This only includes repair and reuse of products handed in at waste collection centres, it does not include the secondary market.

The potential for reduction of plastics in EEE is limited to around 12% relative to the baseline demand projection for all categories except industrial cables¹⁹.

Dematerialisation strategies in EEE are multifaceted and current trends already indicate a movement towards, for example, more compact devices, an increased use of cloud computing, and device consolidation where a single device could be used to provide many services. By leveraging these shifts, it is estimated that 10% of plastics in current consumer-facing EEE can be eliminated.

There are five major downstream levers that should be prioritised in the short term to ensure higher rates of mechanical recycling.

Maximising formal collection of WEEE should be the first priority. It is the most impactful lever in the short term and is critical for gaining greater control over WEEE and avoiding adverse environmental impacts, particularly in other countries.

The Norwegian system currently faces three main collection challenges: theft at collection points, incorrect disposal in mixed waste, and industrial cables being left underground and never recovered. Overcoming these

challenges, particularly theft at collection points, requires much more stringent enforcement of existing policy.

Incorrect disposal has declined as a result of information campaigns from the PROs (Producer Responsibility Organisations) and the introduction of take back schemes in Norway. While this has been particularly effective for higher value items, progress has stagnated recently and incorrect disposal rates have plateaued, with lower value items still being incorrectly disposed of.

Financial incentives and disincentives, particularly deposit return schemes and fines, can reduce incorrect disposal to much lower levels. In fact, by leveraging these opportunities, incorrect disposal could be minimised to 2% by 2040.

There is existing policy in Norway mandating that old cables are removed, but extracting them is a costly process. Through better enforcement of this policy, removal rates could increase from around 60% to 90% by 2040. However, it is important to consider that it is not always technically feasible to remove old cables, nor always better from an environmental perspective.

Reuse is a very underutilised opportunity; many products are discarded prematurely, indicating significant potential for reuse. However, most reuse is likely to occur abroad.

There is significant opportunity for collected WEEE products to be refurbished and resold for further use, but there are two major challenges.

Firstly, the lack of demand for second-hand products in Norway, both for lower value products due to the low cost of replacing items with new products, as well as for higher value products where there is not the same level of guarantees as there are for new products. Secondly, on the supply-side, there is a lack of focus at collection points on identifying items that could be refurbished and reused.

Another example of innovative technologies being tested and scaled is the sorting line provided by Belgian company, Advanced Design of Recycling Machines (AD REM), and German company Hamos, which has already been deployed in the UK and Japan. The process involves two float-sink tank stages, to recover the polyolefins, as well as electrostatic separation to separate the PS and ABS. Investment in scaling these advanced technologies as well as in further R&D is critical and should be supported by policy, for example by setting recycled content targets and material-specific recycling rates.

Mechanical recycling capacity should be expanded to support the 220% growth in recycling needed to cope with the much larger volumes of waste. However, many facilities in Norway typically operate at only 60%-70% capacity due to unfavourable economics. With higher recyclate prices, and greater demand for recyclates, recyclers will be incentivised to maximise their capacity utilisation factor. In addition, extra capacity must be built, either within Norway or in collaboration with neighbouring countries, to meet the 36,000 tonnes of mechanical recycling required for WEEE plastics by 2040.

Finally, chemical recycling should tackle plastics which are unsuitable for mechanical recycling, particularly those which contain brominated flame retardants, as well as plastics from old industrial cables. While chemical recycling is a nascent technology, requiring more research, it is expected to play an important role for WEEE plastics under the System Change Scenario, with 23% (~17,000 tonnes) of demand for utility chemically recycled by 2040 and recirculated back into the system.