Dell’s Producer Responsibility Policy is based on more than a decade of experience providing recycling and re-use services directly to our customers. To meet customer needs at product end of life as a part of the total value of the Dell customer relationship we provide, direct to the consumer, free end-of-life management for: 
  • Any Dell branded product from individual consumers; and 
  • Any brand of electronic product when an individual consumer purchases a similar new product from Dell
In addition to the provision of convenient recycling services through partners,
networks or public collection points.

Furthermore, Dell is: 
  • Expanding these same programs globally across all consumer product lines and continually working to meet the demands of all our customers and expand our recovery and recycling operations wherever our business grows.
  • Committed to transparent and effective goal setting and public reporting on our end-of-life recovery programs. 
  • Offering a commercial Asset Resale and Recycling service to meet the specific needs of our commercial customers.
Dell integrates the principles of Individual Producer Responsibility into its own policy under which all producers take responsibility for proper end of life product management of their own electronic products, enabling internalization of the end of life costs of a producers own brand that can in turn enable the continual review of the eco-design of the products. 

Dell also supports the establishment of complementary collective solutions where industry stakeholders work together establishing common collection networks with a view to increasing the volumes of products collected. 

Dell is committed to providing efficient and easy product recovery options directly to customers to facilitate responsible product retirement with or without mandates. We accept responsibility for continually improving the environmental design aspects of our products and their end-of-life management. We have consistently been an IT industry leader in disposal convenience for consumers and overall volume of collections. This includes jurisdictions without recycling laws as well as those with laws that require collection by producers but do not set targets. Dell encourages this same level of responsibility and investment from other IT producers and indeed, all producers of all electrical products. Only then can there be a level playing field and a full commitment by all producers that will increase collection volumes and ensure proper end-of-life treatment of electronic and electrical products.

Principles for Product Recovery Legislation
  • Producers must be required to offer end-of-life recovery of their own brand of products from consumers at no charge, through their own recycling/reuse collection programs, and/or through an industry collective program, which ensure that all producers take responsibility for the collection and treatment of end of life product equal to their fair share of the total e-waste generated.
  • Producers must have the flexibility to implement varying collection systems which provide free and reasonably convenient collection or return of end-of-life products for consumers. 
  • Dell recognizes the need for effective regulatory enforcement by the government to ensure that all producers, and indeed all stakeholders, are assuming a fair share of the responsibilities and costs of a comprehensive recycling program. This includes other producers, recyclers, collectors, retailers and consumers. 
  • Dell does not support arbitrary collection targets that are unsustainable over the long term, do not reflect changes in consumer demands or product composition and can cause market manipulation and pricing distortions that unnecessarily increase costs. 
  • Any company that manufactures or has manufactured an electronic product must create a Web site that provides instructions on how consumers can use their return process. Governments also have a role to assist producers in driving awareness of proper disposal options and should also promote awareness of the legislation. 
  • Producers of electronic products within the product scope of legislation must be required to include a label on their products sufficient to identify the brand. Producers, resellers and retailers should not be allowed to sell products that do not include an identifiable brand label of the producer. 
  • Any legislation for free electronic product recycling should focus on consumers. Currently, commercial organizations already are responsible for disposition of their products and avail themselves of producers’ asset recovery services. Dell launched its own Asset Resale and Recycling Service for commercial customers of all sizes more than a decade ago.
  • Governments should not apply fees on producers to finance the creation of government infrastructure to collect and process end-of-life electronics. Dell opposes visible or external fees imposed on consumers at the time of purchase or at the end of the useful life of electronic products. 
  • Consumers should remain responsible for removing their personal data from any products they return.
  • Legislation should establish or require recycling standards equivalent with globally recognized standards to ensure that materials are managed in an environmentally sound manner, ensuring a level playing field for all recyclers.
  • Producers must have the flexibility to internalize the end-of-life costs of their own products that can in turn reduce costs and enable the continual review and improvement of the eco-design of the products.
Background Details on Specific Principles for Product Recovery Legislation

Dell has engaged directly with all stakeholders, including customers, recyclers, retailers and government, to help shape our legislative position, which is based on the following:

Collection
  • In order to ensure that all producers are taking responsibility for their share of the e-waste generated they must demonstrate they are collecting end of life product equivalent to their market share of new products being placed on the market in their product categories; including the producers own collection. This can be effectively calculated using e-waste projection models that account for product lifecycle and allow for re-use volumes, reflecting the actual volumes of e-waste generated in a market in a given time frame such as current or previous year/s. Collective systems would be responsible for collecting the required amount of end of life product based on the aggregate market share of its members. Market share should be determined using actual sales data.
  • Producers must meet their obligation by collecting products in their own product categories utilizing individual or collective systems. For example, IT producers’ obligation would be met by collecting IT products, including computers, and peripherals associated with computers, such as monitors, keyboards, mice, printers, external hard drives, etc. Producers with products in multiple categories (e.g. TV’s and IT products) would collect products in those same categories. Producers may join a collective system and pay proportionate share of the collective costs based on their market share in each category. This prevents cross subsidization of the cost of recycling products with little residual value (e.g. TV’s) by producers of products with residual value (e.g. IT). It also prevents stockpiling of certain products by collectors and processors to inflate the price of these products in the market.
  • Any costs imposed on producers as part of the registration process should be minimal and used only to defray the administrative costs of the registration and compliance process, not for government-financed recycling infrastructure. 
  • For transparency on overall volumes collected, collection sites not managed by producers/collectives (e.g., municipalities, non-profits, recyclers) must report weight of end of life product collected by product category (e.g., IT, TV). 
  • Dell believes that a free market should be the best determinant of the price paid by producers for the collection of their products by others. However, where the market does not or cannot ensure a fair price, there must be a transparent process for setting the price paid by producers to municipalities, non-profits, recyclers and others to prevent inflated pricing and profiteering by these collection agents. The process must include verifiable and auditable reports of costs incurred by these collectors to ensure that the price set does not contain unnecessary or inflated costs. 
  • Governments should not mandate visible or external fees on consumers, either at time of purchase or at time of disposal of electronic products, to finance the costs of processing electronic products at the end of their useful life. 
  • Government legislation and regulation should establish or require recycling standards equivalent with globally recognized standards for electronics recyclers to ensure that materials are managed in an environmentally sound manner from the point of collection to final treatment, including reporting requirements, worker health and safety criteria, and penalties for violations. This ensures a level playing field which is critical for environmental protection and ensuring the economic stability of the recycling market. 
  • Our commitment as an organisation is to be responsible for our own brand. We recognise that not all producers act responsibly and with the implementation of varying producer responsibility models, we will at times be required to take reasonable responsibility for others orphaned brands however Government should first take responsibility to identify these brand owners to assign appropriate responsibility for their products.

Bans

  • Dell would not oppose a landfill ban on end-of-life IT products where other more appropriate treatment is locally available.
  • Dell would not oppose a ban on certain materials in IT products, consistent with Europe’s Restriction of the Use of Certain Hazardous Substances (RoHS) directive.
  • Dell would not oppose a prohibition of Electronic Waste to be exported from developed (OECD/EU) to developing (non-OECD/EU) countries. Electronic waste is classed as non-functional product and associated parts. Dell would not oppose prohibition of the use of prison labor in recycling electronics.

Prerequisites for Successful Product Recovery Legislation

  • Producer Responsibility mandates based on Dell Principles for Product Recovery Legislation have the capacity to provide efficient and easy product recovery options directly to customers to facilitate responsible product retirement, no matter the jurisdiction. However, the benefits of such legislation will only be realized after certain laws, regulations and infrastructures are put in place.
  • Government must be ready for such an approach and must be prepared to support local communities, commercial organizations and consumers to develop a culture and practice of responsible recycling. Many regions, however, do not yet have the necessary elements in place to ensure proper handling of waste materials and end-of-life electronics.
  • Before the Dell electronics recovery principles should be considered for any particular country, that country first should have in place the following three measures, each of which is necessary to ensure that appropriate human health and environmental standards are met and that the resulting recycling is beneficial, not harmful, to the community.
    • Regulation of General Waste Handling: The government must adopt a robust set of laws and rules — including education, monitoring and enforcement — to ensure the safe handling and disposition of waste materials in general.
    • General Waste Handling Physical Infrastructure: Infrastructure must exist to enable appropriate collection, transportation, dismantling and disposition of equipment — along with the training of workers — to ensure proper handling of waste materials in general.
    • Reformation of Unregulated Informal Recycling Markets: With the necessary regulatory policies and physical infrastructure in place to address waste in general, specific measures must also be taken to eliminate the unsafe recycling of end-of-life electronics with existing unregulated informal recycling operations.
  • Dell stands ready to work with governments to share its experience, best practices and to identify appropriate systems to manage end-of-life electronics within their borders so that the benefits of the Dell Principles for Product Recovery Legislation can be fully realized.